§ 1.482-9(m)(2) Services transactions that effect a transfer of intangible property.

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A transaction structured as a controlled services transaction may in certain cases include an element that constitutes the transfer of intangible property or may result in a transfer, in whole or in part, of intangible property. Notwithstanding paragraph (m)(1) of this section, if such element relating to intangible property is material to the evaluation, the arm’s length result for the element of the transaction that involves intangible property must be corroborated or determined by an analysis under § 1.482-4.

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