Arm's length pricing method selection depends on transaction facts, comparability, reliable data, and accurate adjustments. The most appropriate method for determining an arm's length price is the method best suited to the facts and circumstances of the particular international transaction or specified domestic transaction, and the method that provides the most reliable measure of that price. Selection depends on the transaction's nature and class, the associated enterprises involved, the functions performed, the availability and reliability of data, comparability, the scope for accurate adjustments, and the nature, extent and reliability of assumptions required in applying the method.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Arm's length pricing method selection depends on transaction facts, comparability, reliable data, and accurate adjustments.
The most appropriate method for determining an arm's length price is the method best suited to the facts and circumstances of the particular international transaction or specified domestic transaction, and the method that provides the most reliable measure of that price. Selection depends on the transaction's nature and class, the associated enterprises involved, the functions performed, the availability and reliability of data, comparability, the scope for accurate adjustments, and the nature, extent and reliability of assumptions required in applying the method.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
