TRANSFER PRICING QUESTION: (Has to do with the specified transfer pricing methods)

Explain for each specified method how each of the following impact the Arms 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)