While this solution sounds logical and simple at first glance,
one can also imagine where the problem lies: it takes a lot
of work to determine whether a company is following the
ALP for all its transactions. Furthermore, the correct comparable
price is not easy to find, since many transactions
are unique. To sidestep this problem, there are various
methods that attempt to improve the calculation of comparable
prices; they include, for example, the »cost plus«
method, where the production costs of the goods are calculated,
and then a reasonable profit margin is added.
However, there are many goods that are hard to compare,
no matter which calculation method is applied.
This is particularly the case for intangible goods such
as intellectual property rights. Patents or licences are by
definition unique. This is exactly why they are property
rights. It is therefore extremely difficult, if not impossible,
to find a comparable price for these goods