Whether results derived from applications of this method are the most reliable measure of the arm’s length result must be determined using the factors described under the best method rule in § 1.482-1(c). The application of these factors under the resale price method is discussed in paragraphs (c)(3) (ii) and (iii) of this section.
§ 1.482-3(c)(3)(i) In general.
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By Internal Revenue Service
Category: US IRC Section 482 on Transfer Pricing, § 1.482-3 Methods to determine taxable income in connection with a transfer of tangible property | Tag: Best method rule, Buy-sell distributor, Gross profit margin, Purchase and resale, Resale Price Method (RPM)
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