Consistent with the principles of paragraphs (f)(2)(i)(A) and (B) of this section, a coordinated best method analysis and evaluation of two or more controlled transactions to which one or more provisions of the Code or regulations apply may be necessary to ensure that the overall value provided, including any synergies, is properly taken into account. A coordinated best method analysis would include a consistent consideration of the facts and circumstances of the functions performed, resources employed, and risks assumed in the relevant transactions, and a consistent measure of the arm’s length results, for purposes of all relevant statutory and regulatory provisions.
§ 1.482-1T(i)(C) Coordinated best method analysis and evaluation.
Category: Transfer Pricing Guidelines, US IRC Section 482 on Transfer Pricing, § 1.482-1T Allocation of income and deductions among taxpayers (temporary). | Tag: Actual transaction, Aggregated transactions, Aggregation, Best Method Rule, Entire arrangement, Form or character of the transaction, Labels, Most appropriate method (MAM), Most appropriate net profit indicator
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Next » Related Guidelines
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