Whether a method provides the most reliable measure of an arm’s length result also depends upon the completeness and accuracy of the underlying data, the reliability of the assumptions, and the sensitivity of the results to possible deficiencies in the data and assumptions. Such factors are particularly relevant in evaluating the degree of comparability between the controlled and uncontrolled transactions. These factors are discussed in paragraphs (c)(2)(ii) (A), (B), and (C) of this section.
§ 1.482-1(c)(2)(ii) Data and assumptions.
Category: (c) Best method rule, Transfer Pricing Guidelines, US IRC Section 482 on Transfer Pricing, § 1.482-1 Allocation of income and deductions among taxpayers | Tag: Best Method Rule, Degree of comparability, Most appropriate method (MAM), Most reliable data, Reliable information
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