What US Treasury Regulations 26 CFR Section 1.482 Transfer Pricing Rules - Arm's Length Standard, Comparable Uncontrolled Price (CUP), Cost Plus, Resale Price and Profit Split Methods requires
Under 26 CFR § 1.482-1(b), the U.S. Internal Revenue Service (IRS) requires that transactions between commonly controlled entities must adhere to the 'arm's length standard,' meaning the results of the transaction must be consistent with the results that would have been realized if uncontrolled taxpayers had engaged in the same transaction under the same circumstances.
Pillar: Banking & Global Finance · Authority: Internal Revenue Service (IRS), U.S. Department of the Treasury · Version: 1.0.0 · Last updated:
Primary source: https://www.irs.gov/businesses/international-businesses/transfer-pricing
SHA-256 integrity: ae3141a2a996aeb6cd82a177bd3df3b5d744948a372cdafcf485baf8a5920644
Primary Citations — 8 traced to source
- 26 CFR § 1.482-1 - Allocation of income and deductions among taxpayers
- 26 CFR § 1.482-2 - Determination of taxable income in specific situations
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