See § 1.482-1(e)(2) for the determination of the arm’s length range. For purposes of the comparable profits method, the arm’s length range will be established using comparable operating profits derived from a single profit level indicator.
§ 1.482-5(b)(3) Arm’s length range.
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By Internal Revenue Service
Category: US IRC Section 482 on Transfer Pricing, § 1.482-5 Comparable profits method | Tag: Arm’s length range, Comparable Profits Method (CPM), Transactional net margin method (TNMM)
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