Tag: Profitability

The ability of a company to earn a profit.

§ 1.482-3(a) In general.

The arm’s length amount charged in a controlled transfer of tangible property must be determined under one of the six methods listed in this paragraph (a). Each of the methods must be applied in accordance with all of the provisions of § 1.482-1, including the best method rule of § 1.482-1(c), the comparability analysis of § 1.482-1(d), and the arm’s length range of § 1.482-1(e). The methods are – (1) The comparable uncontrolled price method, described in paragraph (b) of this section; (2) The resale price method, described in paragraph (c) of this section; (3) The cost plus method, described in paragraph (d) of this section; (4) The comparable profits method, described in § 1.482-5; (5) The profit split method, described in § 1.482-6; and (6) Unspecified methods, described in paragraph (e) of this section ... Read more