§ 1.482-9(f)(1) In general.

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The comparable profits method evaluates whether the amount charged in a controlled transaction is arm’s length, based on objective measures of profitability (profit level indicators) derived from uncontrolled taxpayers that engage in similar business activities under similar circumstances. The rules in § 1.482-5 relating to the comparable profits method apply to controlled services transactions, except as modified in this paragraph (f).

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