美国转让定价指导性文件.pdf

TITLE 26 -- INTERNAL REVENUE CHAPTER I -- INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY SUBCHAPTER A -- INCOME TAX PART 1 -- INCOME TAXES NORMAL TAXES AND SURTAXES DEFERRED COMPENSATION, ETC. METHODS OF ACCOUNTING ADJUSTMENTS 26 CFR 1.482-0 搂 1.482-0 Outline of regulations under 482. This section contains major captions for 搂搂 1.482-1 through 1.482-8. Section 1.482-1 Allocation of income and deductions among taxpayers. (a) In general. (1) Purpose and scope. (2) Authority to make allocations. (3) Taxpayers use of section 482. (b) Arms length standard. (1) In general. (2) Arms length methods. (i) Methods. (ii) Selection of category of method applicable to transaction. (c) Best method rule. (1) In general. (2) Determining the best method. (i) Comparability. (ii) Data and assumptions. (A) Completeness and accuracy of data. (B) Reliability of assumptions. (C) Sensitivity of results to deficiencies in data and assumptions. (iii) Confirmation of results by another method. (d) Comparability. (1) In general. (2) Standard of comparability. (3) Factors for determining comparability. (i) Functional analysis. (ii) Contractual terms. (A) In general. (B) Identifying contractual terms. (1) Written agreement. (2) No written agreement. (C) Examples. (iii) Risk. (A) In general. (B) Identification of party that bears risk. (C) Examples. (iv) Economic conditions. (v) Property or services. (4) Special circumstances. (i) Market share strategy. (ii) Different geographic markets. (A) In general. (B) Example. (C) Location savings. (D) Example. (iii) Transactions ordinarily not accepted as comparables. (A) In general. (B) Examples. (e) Arms length range. (1) In general. (2) Determination of arms length range. (i) Single method. (ii) Selection of comparables. (iii) Comparables included in arms length range. (A) In general. (B) Adjustment of range to increas