If the controlled taxpayer is comparable to a sales agent that does not take title to goods or otherwise assume risks with respect to ownership of such goods, the commission earned by such sales agent, expressed as a percentage of the uncontrolled sales price of the goods involved, may be used as the comparable gross profit margin.
§ 1.482-3(c)(3)(ii)(D) Sales agent.
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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: Ownership of goods, Resale Price Method (RPM), Sales agent
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