Explain for each specified method how each of the following impact the Arms Length Standard: 1. Substance
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Question:
Explain for each specified method how each of the following impact the Arm’s Length Standard:
1. Substance over form; 2. Multi-year data; 3. Interquartile range.
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)
Related Book For
Income Tax Fundamentals 2013
ISBN: 9781285586618
31st Edition
Authors: Gerald E. Whittenburg, Martha Altus Buller, Steven L Gill
Posted Date: