Extract to table

Where material differences exist between the controlled and uncontrolled transactions, adjustments must be made to account for those differences under Treasury Regulation § 1

482-4(c)(2)(ii), or the purported comparable must be rejected

482-4(c)(2)(ii) expressly requires that if there are material differences between the controlled and uncontrolled transactions, adjustments must be made to account for those differences

482-1(c) provides that the arm's-length result of a controlled transaction must be determined under the method that, under the facts and circumstances, provides the most reliable measure of an arm's-length result (the "best method rule")

The regulation is explicit that RABs must be determined on a prospective (ex ante) basis, using projections of benefits made at the beginning of each cost-sharing period

482-7(d), which specifies the categories of costs that must be included in the Coss pool for purposes of determining each participant's cost-sharing obligation