RmaNcs (No. 2) 201s No,9 Eva.luatirsn of taxp{ey e.r's cornbined controlled trttnsactiorus 5. If a taxpayer carries out, under the same or similar circumstances or more c.ontrolled transactions that are econornically closely linked to one another or that forrn a continuum such that they cannot reliably be analysed separately, those transactions may be combined to (i) perform the comparability analysis set out in paragraph 3 and (ii) apply the transfer o tr,vo pricing methods set out in paragraph 5, Arrn's len.gth range 6. ( 1) An arm's length range is a range of relevant f,nancial indicator figures (e.g. prices, Inargins or profit shares) produced by the application of the most appropriate transfer pricing method as set out in paragraph 4 to a number of uncontrolled transactions, each of which is relatively equally comparable to the controlled transaction based on a comparability analysis conducted in accordance r'vith paragraph 3. (Z) A controlled transaction, or a set of transactions that are combined according to paragraph 5 shall not be subject to an adjustment under section 988 rvhere the relevant financial indicator derived from the controlled transaction or set of transactions and being tested under the appropriate transfer pricing method is r'vithin the arm's length range. (3 ) \{r here the relev ant fi nancial i ndicator deriv ed from a c ontro lle d transaction, or from a set of transactions that are coffrbined according to paragraph 5, falls outside the arm's length range, the Commissioner may adjust it pursuant to section 988(1), and any such acljustment shall be to the median in the armos length range. (4) For the purposes of subparagraph {3), the median of the arm's length range shall be the 50th percentile of the financial indicator figures derived from the comparable uncontrolled transactions forrning the arm's length range. For this purpose, the 50th percentile is the lowest financial indicator figure such that at least 50 trlercent of the financial indicator figures are at or below the value of that figure. I{olvever, if exactly 50 percent of the results are at or below a f,nancial indicator figure, then the 50th percentile is equal to the arithmetic mean of that figure and the next highest flgure. S ource s of infn rrnati,rsn oru comparabl e t*rcontrotled trans actiorts 7 . (1) Possible sources of information on comparable uncontrolled transactions that may include- (a) internal uncontrolled transactions,, which are uncontrolled transactions where one of the parties to the controlled transaction is also a party to the uncontrolled transaction: and (b) external uncontrolled transactions, which are uncontrolled transactions to lvhich neither of the parties to the controlle d transac.tion is a pafiy. (2) Information concerning a comparable external uncontrolled transaction may not be relied upon by the Commissioner for the purposes of making an adjustment under section 988 if the information concerning the transaction is not available to the taxpayer. 187