Arm's length price determination uses dataset percentiles, weighted averages, and median-based valuation for comparable transactions. Determination of arm's length price applies where the most appropriate method for an international transaction or specified domestic transaction yields more than one price. The prices are arranged in ascending order to form a dataset, with weighted averages of comparable uncontrolled transactions included or excluded according to the current-year and preceding-year data rules. Where six or more entries exist, an arm's length range from the 35th percentile to the 65th percentile applies; if the actual price falls outside that range, the median is used, and where the range does not apply, the arithmetical mean or the permitted tolerance rule governs.
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Arm's length price determination uses dataset percentiles, weighted averages, and median-based valuation for comparable transactions.
Determination of arm's length price applies where the most appropriate method for an international transaction or specified domestic transaction yields more than one price. The prices are arranged in ascending order to form a dataset, with weighted averages of comparable uncontrolled transactions included or excluded according to the current-year and preceding-year data rules. Where six or more entries exist, an arm's length range from the 35th percentile to the 65th percentile applies; if the actual price falls outside that range, the median is used, and where the range does not apply, the arithmetical mean or the permitted tolerance rule governs.
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