A controlled services transaction may be analyzed as two separate transactions for purposes of determining the arm’s length consideration, if that analysis is the most reliable means of determining the arm’s length consideration for the controlled services transaction. See the best method rule under § 1.482-1(c).
§ 1.482-9(l)(4) Disaggregation of transactions.
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By Internal Revenue Service
Category: US IRC Section 482 on Transfer Pricing, § 1.482-9 Methods to determine taxable income in connection with a controlled services transaction | Tag: Disaggregation of transaction, Intra-group services, Services
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