CUP Method: Could It Be a Reliable “Sanity Check” When the Arm’s Length Principle Is Verified Using a Transactional Profit Method?

Automatic year’s end adjustments deriving from the application of the transactional net margin method could trigger under specific circumstances inconsistencies with the underlying transactions. The application of the transactional net margin method cannot disregard the price of the goods when the significant economic terms and conditions are substantially comparable, and, notwithstanding that the comparable uncontrolled price method does not satisfy all the conditions to be applied as most preferable transfer pricing method, it could improve the level of reliability of the transfer pricing analysis.