If a controlled taxpayer is comparable to a purchasing agent that does not take title to property or otherwise assume risks with respect to ownership of such goods, the commission earned by such purchasing agent, expressed as a percentage of the purchase price of the goods, may be used as the appropriate gross profit markup.
§ 1.482-3(d)(3)(ii)(D) Purchasing 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: Cost plus method, Gross Margin, Gross profit margin, Gross profit markup, Procurement, Purchasing agent, Trading hub
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