The methods described in §§ 1.482-2 through 1.482-6 are generally stated in terms of individual transactions. However, because a taxpayer may have controlled transactions involving many different products, or many separate transactions involving the same product, it may be impractical to analyze every individual transaction to determine its arm’s length price. In such cases, it is permissible to evaluate the arm’s length results by applying the appropriate methods to the overall results for product lines or other groupings. In addition, the arm’s length results of all related party transactions entered into by a controlled taxpayer may be evaluated by employing sampling and other valid statistical techniques.
§ 1.482-1(f)(2)(iv) Product lines and statistical techniques.
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By Internal Revenue Service
Category: US IRC Section 482 on Transfer Pricing, § 1.482-1 Allocation of income and deductions among taxpayers | Tag: Determination of taxable income, Product line, Statistical techniques, Statistical tools, Transfer pricing audit, Transfer pricing disputes
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