FniaNcs (No. 2) 2015 No,9 (3) Where it is possible to identity' specific services provided by a taxpayer to a associated person, the determination whether the service charge is consistent with the arrn's length principle shall be made for each speciflc sen'ice, subject to the provisions of subparagraph (4) (4) Where servic.es ars rendered by a taxpayer jointly to various associated persons and it is not possible to identify specif,c sen'ices provided to each of thern, the total service charge shall be allocated among the associaterJ persons that benefit or expect to tlenefit from tlrc seruices according to reasonable allocation criteria" (5) For the purpose of this paragraph, allocation criteria shall be viewed as reasonable lvhere they are based on a variable or variables that- (a) take into ac.c.ountthe nature of the services,the circumstances under n'trrich they are prcvided and the benefits obtained or that were expected to be obtained by the persons for rvhich the services are intended; and (b) relate exclusively to uncontrolled, rather than controlled, transactions; and (c) are capable of being in a reasonably measured reliable manner. Transaction.s involving irztangible property 9, (1) The determination of arm's length conditions for controlled transactions involving licences, sales or other transfers of intangible property between associated persons shall take inio account both the perspective of the transferor of the property and the perspectir.e of the transferee, including in particular the pricing at which a comparable independent enterprise rvould be willing to transfer the property and the value and usefulness of the intangibte property to the transferee in its business. (2) In applying the pravisions of paragraph 3 to a transaction involving the licence, sale or other transfer of intangible property, consideration shall be given to any special factors relevant to the comparability of the controlled and uncontrolled transactions, including - (a) (b) the expected benefits from the intangible prop*fry; and (c) the exclusive or non-exclusive character of the rights any geographic lirnitations on the exercise of rights to the intangible property; and transferred; and (d) whether the transferee has the right to participate in ft.rrther developments of the intangible property by the transferor. C rt r re s p o n d,i rt g a dj us {t'ne n ts fo, d.ome s ic t r tuts nc t ion s t 10. ( 1) The determination of arm's length conditions for controlled transactions involving licences, sales or other transfers of intangible property between associated persons shall take into account both the perspective of the transferor of the property and tlie perspective of the transferee, including in particular the pricing at rvhich a comparable independent enterprise would be rvilling to transfer the property and the value and usefulness of the intangible property to the transferee in its business. 189