In general.

(a)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 applied in accordance with all of the provisions of § 1.482-1, including the best method rule of § 1.482-1(c), the comparability analysis of § 1.482-1(d), and the arm's length range of § 1.482-1(e). The arm's length consideration for the transfer of an intangible determined under this section must be commensurate with the income attributable to the intangible. See § 1.482-4(f)(2) (Periodic adjustments). The available methods are—

(1)The comparable uncontrolled transaction method, described in paragraph (c) of this section;

(2)The comparable profits method, described in § 1.482-5;

(3)The profit split method, described in § 1.482-6; and

(4)Unspecified methods described in paragraph (d) of this section.