Extract to table

In practice, both parties in a transfer pricing dispute must present affirmative evidence supporting their respective proposed arm's-length results

Internal CUTs are generally considered more reliable than external CUTs because they involve the same intangible property and one of the same parties, thereby reducing the number of comparability differences that must be evaluated and adjusted

The regulations provide both general and specific comparability factors that must be considered in evaluating whether an uncontrolled transaction is comparable to the controlled transaction under review

These general factors provide the overarching framework for comparability analysis and must be considered in conjunction with the method-specific factors

Comparables must be evaluated for the geographic scope of the rights conferred, the exclusivity or non-exclusivity of the grant, and any field-of-use restrictions

482-1(c) establishes the "best method rule," which 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