Section 1.482-7 provides the specific methods to be used to determine arm’s length results of controlled transactions in connection with a cost sharing arrangement. This section provides the specific methods to be used to determine arm’s length results of a controlled service transaction, including in an arrangement for sharing the costs and risks of developing intangibles other than a cost sharing arrangement covered by § 1.482-7. In the case of such an arrangement, consideration of the principles, methods, comparability, and reliability considerations set forth in § 1.482-7 is relevant in determining the best method, including an unspecified method, under this section, as appropriately adjusted in light of the differences in the facts and circumstances between such arrangement and a cost sharing arrangement.
§ 1.482-9(m)(3) Coordination with rules governing cost sharing arrangements.
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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: Intra-group services, Services
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