armslength
armslength

In general.

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 wit...

Cite as:Treas. Reg. § 1.482-9(a)
26 CFR Part 1

Full Text

(a)

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 with 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), except as those provisions are modified in this section. The methods are—

(1)

The services cost method, described in paragraph (b) of this section;

(2)

The comparable uncontrolled services price method, described in paragraph (c) of this section;

(3)

The gross services margin method, described in paragraph (d) of this section;

(4)

The cost of services plus method, described in paragraph (e) of this section;

(5)

The comparable profits method, described in § 1.482-5 and in paragraph (f) of this section;

(6)

The profit split method, described in § 1.482-6 and in paragraph (g) of this section; and

(7)

Unspecified methods, described in paragraph (h) of this section.

Source: 26 CFR § 1.482-9 via Electronic Code of Federal Regulations (eCFR) · View on Cornell Law

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