In some cases, it may be necessary to allocate one or more portions of the arm’s length result that was properly determined under a coordinated best method analysis described in paragraph (f)(2)(i)(C) of this section. Any such allocation of the arm’s length result determined under the coordinated best method analysis must be made using the method that, under the facts and circumstances, provides the most reliable measure of an arm’s length result for each allocated amount. For example, if the full value of compensation due in controlled transactions whose tax treatment is governed by multiple provisions of the Code or regulations has been most reliably determined on an aggregate basis, then that full value must be allocated in a manner that provides the most reliable measure of each allocated amount.
§ 1.482-1T(i)(D) Allocations of value.
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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