Extract to table

Under this standard, controlled transactions — that is, transactions between related parties — must reflect terms and conditions that would have been agreed upon between unrelated parties dealing at arm's length under comparable circumstances

The controlled taxpayer's dealings with the commonly controlled entity must yield results consistent with those that would have been realized if uncontrolled taxpayers had engaged in the same transaction under the same circumstances

The taxpayer, in turn, must demonstrate that it applied a reasonable transfer pricing methodology and maintained adequate documentation to support its pricing

482-4(a) provides that the arm's-length consideration for the transfer of intangible property must be "commensurate with the income attributable to the intangible

Each of these factors must be evaluated in determining whether an uncontrolled transaction is sufficiently comparable to the controlled transaction to serve as a reliable benchmark