What does CUP stand for?

Comparable Uncontrolled Price (accounting)

This definition appears very rarely and is found in the following Acronym Finder categories:

Business, finance, etc.

Other Resources:

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Samples in periodicals archive:

The CRA made a bid to apply the comparable uncontrolled price (CUP) method and adjust the transfer price Glaxo had paid on ranitidine on the basis that Glaxo had paid a higher price to SwissCo than would have been reasonable if the companies were dealing at arm's length.

Lessons from the Tax Court of Canada's Glaxo Decision

While the dispute with the IRS focused on the creation of marketing intangibles in the United States, the Canadian case developed on a different footing: the use of generic prices by the Canada Revenue Agency (CRA) as a Comparable Uncontrolled Price (CUP).

The Glaxo Canada tax case: a bitter pill

This is a parallel method to the tangibles' comparable uncontrolled price ("CUP") method, (207) adjusted for the fact that with intangibles it is rare to have comparable transactions with similar enough properties.

Value in the eye of the beholder: the valuation of intangibles for ...

482-2A(e)(2)) which sets forth rules for computing arm's-length prices under the comparable uncontrolled price method.

Computation of combined taxable income of possession corporations ...

These methods include: The Comparable Uncontrolled Price Method ("CUP").

China's New Transfer Pricing Implementation Rules

482-3(a), the most commonly accepted methods for obtaining an arm's-length price are the: (1) comparable uncontrolled price (CUP) method; (2) resale price (RP) method; (3) cost plus (CP) method; (4) comparable profits method; and (5) profit split (PS) method.

Not all transfer-pricing rules are created equal

Administratively, Revenue Canada has adopted the 1979 OECD guidelines(5) and, in respect of transfers of tangible property, has looked to the comparable uncontrolled price (CUP) method, the resale-price method, the cost-plus method, and other methods.

Canadian release increases fears of U.S.-Canadian transfer pricing ...

The Court endorsed the ordering of methods set out in the OECD's Transfer Pricing Guidelines, concluding that the comparable uncontrolled price ("CUP") method was the preferred method for determining a reasonable price for the taxpayer's purchase of ranitidine, unless there was no comparable transaction.

Canada's Tax Court Decides First Transfer Pricing Case