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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) derive...
Treas. Reg. § 1.482-5(a)(a)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) derived from uncontrolled taxpayers that engage in similar business activities under similar circumstances.
Source: 26 CFR § 1.482-5 via Electronic Code of Federal Regulations (eCFR)
See this section in context within the complete § 1.482-5 regulation.
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