Official annual CFR pages for Treasury Regulations § 1.482-1 through § 1.482-9
Browse the full text of U.S. transfer pricing regulations (26 CFR § 1.482) in a readable, navigable format.
Allocation of income and deductions among taxpayers
Purpose and scope. The purpose of section 482 is to ensure that taxpayers clearly reflect…
Determination of taxable income in specific situations
Loans or advances. Interest on bona fide indebtedness. Where one member of a group of con…
Methods to determine taxable income in connection with a transfer of tangible property
The arm's length amount charged in a controlled transfer of tangible property must be det…
Methods to determine taxable income in connection with a transfer of intangible property
The comparable profits method evaluates whether the amount charged in a controlled transa…
Comparable profits method
The comparable profits method evaluates whether the amount charged in a controlled transa…
Profit split method
The profit split method evaluates whether the allocation of the combined operating profit…
Methods to determine taxable income in connection with a cost sharing arrangement
The arm's length amount charged in a controlled transaction reasonably anticipated to con…
Examples of the best method rule
In accordance with the best method rule of §1.482–1(c), a method may be applied in a part…
Methods to determine taxable income in connection with a controlled services transaction
The arm's length amount charged in a controlled services transaction must be determined u…