If there are no variable input parameters, the arm’s length PCT Payment is a single value determined by using the single most reliable value determined for each input parameter.
§ 1.482-7(g)(2)(ix)(D)(1) No variable input parameters.
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By Internal Revenue Service
Category: US IRC Section 482 on Transfer Pricing, § 1.482-7 Methods to determine taxable income in connection with a cost sharing arrangement | Tag: Arm’s length range, CCA/CSA, CCA/CSA - methods for pricing, Cost Contribution Arrangement (CCA), Cost Sharing Arrangement (CSA), Full range, Interquartile range (IQR), Pre-existing intangibles, Statistical tools
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