| BCD-UK plc manufactures a product and sells that product to its parent | corporation, BCD. BCD-UK plc also sells the product to WXY Corp, that | it does not control, at a price of $100 per unit. Except for the | volume of each transaction, the sales to BCD and to WXY Corp take | place under substantially the same economic conditions and contractual | terms. In uncontrolled transactions, BCD-UK plc offers a 2% discount | for quantities of 20 per order, and a 5% discount for quantities of | 100 per order. If BCD purchases the product in quantities of 60 per | order, in the absence of other reliable information, it may reasonably | be concluded that the arm's length price to BCD would be $100, less a | discount of 3.5%. | | http://www.intltaxlaw.com/shared/transfer/regs.htm the scenario some-type uses some-method with controlled seller some-seller1 controlling buyer some-co1 and uncontrolled buyer some-co2 in the scenario that-type the controlling buyer that-co1 purchases items in a quantity some-ctrld-qty the scenario that-type has a base price some-price and an uncontrolled volume discount some-lo-disc for a quantity some-lo-qty the scenario that-type has a base price that-price and an uncontrolled volume discount some-hi-disc for a quantity some-hi-qty that-lo-qty is less than that-hi-qty interpolating between that-lo-qty that-lo-disc and that-hi-qty that-hi-disc yields that-ctrld-qty and some-ctrld-discount that-price discounted by that-ctrld-discount % is some-transfer-price --------------------------------------------------------------------------------------------------------------------------- in the scenario that-type the price for a controlled quantity that-ctrld-qty is that-transfer-price the scenario this-type uses this-method with controlled seller this-co1 controlling buyer this-co2 and uncontrolled buyer this-co3 ================================================================================================================================== d-3-ii arms length method BCD-UK plc BCD Corp WXY Corp in the scenario this-type the controlling buyer this-co purchases items in a quantity this-qty ==================================================================================== d-3-ii BCD Corp 40 d-3-ii BCD Corp 60 the scenario this-type has a base price this-price and an uncontrolled volume discount this-disc for a quantity this-qty ======================================================================================================================= d-3-ii 100 2 20 d-3-ii 100 5 100 100 - some-discount = some-difference that-difference / 100 = some-factor some-price * that-factor = some-discounted-price ----------------------------------------------------------------- that-price discounted by that-discount % is that-discounted-price some-x1 is less than some-x that-x is less than some-x2 that-x2 - that-x1 = some-xdifference some-y1 is less than some-y2 that-y2 - that-y1 = some-ydifference that-x - that-x1 = some-xinterp that-xinterp / that-xdifference = some-xratio that-ydifference * that-xratio = some-ybonus that-y1 + that-ybonus = some-y ---------------------------------------------------------------------------------- interpolating between that-x1 that-y1 and that-x2 that-y2 yields that-x and that-y