Similarity in product characteristics is more relevant when comparing prices than profit margins between controlled and uncontrolled transactions. Comparison of product characteristics is used to a greater extent in the application of the Comparable Uncontrolled Price (CUP) method than any other method. Characteristics that are compared should include:

1. in the case of tangible property: the physical features, quality and the volume of supply of property;
2. in the provision of services: the nature and extent of services; and
3. in the case of intangible property: the form of transaction (e.g. licensing or sale), type of property (e.g. patent, trademark or know how), the duration and degree of protection; and the anticipated benefits from the use of property.