China's 1998 "Regulations on Tax Administration of Business Transactions between Associated Enterprises" stipulates that when adopting the comparable uncontrolled price method, the comparability factors of selected transactions and transactions between affiliated enterprises must be considered, including:

(1) Comparability of the purchase and sale process, including the time and place of the transaction. Delivery terms, delivery procedures, payment terms, transaction quantity, after-sales service time and place, etc. ;

(2) Comparability of purchase and sale links, including ex-factory links and wholesale links. Retail link, export link, etc. ;

(3) Comparability of purchased and sold goods, including name, brand, specification and model. Performance, structure, appearance, packaging, etc. ;

(4) Comparability of purchasing and selling environment, including social environment (national customs, consumer preferences, etc. ), political environment (political stability, etc. ) and economic environment (finance, taxation, foreign exchange policy, etc. ).

From the above factors affecting comparability, it can be seen that the comparable uncontrolled price method is generally difficult to operate, and it is not easy to adopt this method as long as one of the two transactions is incomparable.