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US Treasury Regulations § 1.482

Search and review the full Section 482 framework for controlled transactions, method selection, and compliance.

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26 CFR

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Regulation	Topic	Subsections	Sections	Paragraphs	Open
§ 1.482-1	Allocation of income and deductions among taxpayers In general—(1) Purpose and scope. The purpose of section 482 is to ensure that taxpayers clearly reflect income attributable to controlled transactions and to prevent the avoidance of taxes with...	(a)(b)(c)(d)(e)(f)(g)(h)(i)(j)	10	194	Read
§ 1.482-2	Determination of taxable income in specific situations Loans or advances—(1) Interest on bona fide indebtedness—(i) In general. Where one member of a group of controlled entities makes a loan or advance directly or indirectly to, or otherwise becomes a...	(a)(b)(c)(d)(e)(f)	6	69	Read
§ 1.482-3	Methods to determine taxable income in connection with a transfer of tangible property In general. The arm's length amount charged in a controlled transfer of tangible property must be determined under one of the six methods listed in this paragraph (a). Each of the methods must be...	(a)(b)(c)(d)(e)(f)	6	87	Read
§ 1.482-4	Methods to determine taxable income in connection with a transfer of intangible property In general. The arm's length amount charged in a controlled transfer of intangible property must be determined under one of the four methods listed in this paragraph (a). Each of the methods must be...	(a)(b)(c)(d)(e)(f)(g)(h)	8	88	Read
§ 1.482-5	Comparable profits method In general. The comparable profits method evaluates whether the amount charged in a controlled transaction is arm's length based on objective measures of profitability (profit level indicators)...	(a)(b)(c)(d)(e)	5	40	Read
§ 1.482-6	Profit split method In general. The profit split method evaluates whether the allocation of the combined operating profit or loss attributable to one or more controlled transactions is arm's length by reference to the...	(a)(b)(c)(d)	4	27	Read
§ 1.482-7	Methods to determine taxable income in connection with a cost sharing arrangement In general. The arm's length amount charged in a controlled transaction reasonably anticipated to contribute to developing intangibles pursuant to a cost sharing arrangement (CSA), as described in...	(a)(b)(c)(d)(e)(f)(g)(h)(i)(j)+3	13	432	Read
§ 1.482-8	Examples of the best method rule Introduction. In accordance with the best method rule of § 1.482-1(c), a method may be applied in a particular case only if the comparability, quality of data, and reliability of assumptions under...	(a)(b)(c)	3	22	Read
§ 1.482-9	Methods to determine taxable income in connection with a controlled services transaction In general. The arm's length amount charged in a controlled services transaction must be determined under one of the methods provided for in this section. Each method must be applied in accordance...	(a)(b)(c)(d)(e)(f)(g)(h)(i)(j)+4	14	255	Read

Frequently asked

Section 482 essentials

Concise reference answers for the questions most teams ask first.

1What is Section 482 of the Internal Revenue Code?

Section 482 authorizes the IRS to allocate income, deductions, credits, and other tax items among controlled taxpayers to prevent tax evasion and clearly reflect income.

2What is the arm's length standard under Section 482?

Under Treasury Regulations § 1.482-1(b), controlled transactions should produce results consistent with comparable uncontrolled transactions under comparable circumstances.

3What methods are accepted under Section 482?

Regulations include CUP, Resale Price, Cost Plus, CPM, and Profit Split, with method selection driven by the best method rule in § 1.482-1(c).

4How are services treated under Section 482?

Treasury Regulations § 1.482-9 provides dedicated services methods, including SCM, CUSP, cost of services plus, CPM, and profit split approaches.

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Source: Electronic Code of Federal Regulations. View on eCFR

Regulation

Topic

Subsections

Sections

Paragraphs

Open

§ 1.482-1

Allocation of income and deductions among taxpayers

In general—(1) Purpose and scope. The purpose of section 482 is to ensure that taxpayers clearly reflect income attributable to controlled transactions and to prevent the avoidance of taxes with...

(a)(b)(c)(d)(e)(f)(g)(h)(i)(j)

194

Read

§ 1.482-2

Determination of taxable income in specific situations

Loans or advances—(1) Interest on bona fide indebtedness—(i) In general. Where one member of a group of controlled entities makes a loan or advance directly or indirectly to, or otherwise becomes a...

(a)(b)(c)(d)(e)(f)

Read

§ 1.482-3

Methods to determine taxable income in connection with a transfer of tangible property

In general. The arm's length amount charged in a controlled transfer of tangible property must be determined under one of the six methods listed in this paragraph (a). Each of the methods must be...

(a)(b)(c)(d)(e)(f)

Read

§ 1.482-4

Methods to determine taxable income in connection with a transfer of intangible property

In general. The arm's length amount charged in a controlled transfer of intangible property must be determined under one of the four methods listed in this paragraph (a). Each of the methods must be...

(a)(b)(c)(d)(e)(f)(g)(h)

Read

§ 1.482-5

Comparable profits method

In general. The comparable profits method evaluates whether the amount charged in a controlled transaction is arm's length based on objective measures of profitability (profit level indicators)...

(a)(b)(c)(d)(e)

Read

§ 1.482-6

Profit split method

In general. The profit split method evaluates whether the allocation of the combined operating profit or loss attributable to one or more controlled transactions is arm's length by reference to the...

(a)(b)(c)(d)

Read

§ 1.482-7

Methods to determine taxable income in connection with a cost sharing arrangement

In general. The arm's length amount charged in a controlled transaction reasonably anticipated to contribute to developing intangibles pursuant to a cost sharing arrangement (CSA), as described in...

(a)(b)(c)(d)(e)(f)(g)(h)(i)(j)+3

432

Read

§ 1.482-8

Examples of the best method rule

Introduction. In accordance with the best method rule of § 1.482-1(c), a method may be applied in a particular case only if the comparability, quality of data, and reliability of assumptions under...

(a)(b)(c)

Read

§ 1.482-9

Methods to determine taxable income in connection with a controlled services transaction

In general. The arm's length amount charged in a controlled services transaction must be determined under one of the methods provided for in this section. Each method must be applied in accordance...

(a)(b)(c)(d)(e)(f)(g)(h)(i)(j)+4

255

Read