TRANSFER PRICING QUESTION: (Has to do with the specifiedtransfer pricing methods)
Explain for each specified method how each of the followingimpact the Arm’s Length Standard: 1. Substance over form; 2.Multi-year data; 3. Interquartile range. For each of the aboveinclude the Treasury Regulation section reference and definitionwhen you provide your answer. (Some of the methods are similar, soplease aggregate the response where appropriate)
Specified Methods:
Tangible:
Comparable Uncontrolled Price (CUP)
Resale Price Method (RPM)
Cost-Plus Method (C+)
Profit Split Method (PSM)
Comparable Profits Method (CPM)
Intangible:
Comparable Uncontrolled Transaction (CUT)
Profit Split Method (PSM)
Comparable Profits Method (CPM)
Services:
Comparable Uncontrolled Services Price (CUSP)
Services Cost Method (SCM)
Gross Services Margin Method (GSMM)
Cost of Services Plus Method (COSP)
Profit Split Method (PSM)
Comparable Profits Method (CPM)
TRANSFER PRICING QUESTION: (Has to do with the specified transfer pricing methods) Explain for each specified method how
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