If there are differences between the controlled and uncontrolled taxpayers that would materially affect the division of operating profit, adjustments must be made according to the provisions of § 1.482-1(d)(2).
§ 1.482-6(c)(2)(ii)(B)(2) Adjustments for differences between the controlled and uncontrolled taxpayers.
Posted on | By Internal Revenue Service
Category: US IRC Section 482 on Transfer Pricing, § 1.482-6 Profit split method | Tag: Comparability, Comparability adjustments, Comparable profit split method, Division of profits among uncontrolled parties, Profit split method (PSM)
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