Frx.qncn (No. 2) 2015 F{o.9 through an analysis of the functions undertaken by each person in the controlled transaction, taking into account assets used and risks assumed; and (c) the availability of reliable information needed to apply the selected transfer pricing method or other methods; and (d) the degree of comparability between the controlled and uncontrolled transactions, includirrg the reliability of comparability adjustrnents, if anf, that may be required to eliminate differences between them. (3) It shall not be nec.essary to apply more than one method to determine whether the conditions of a given controlled transaction are consistent rryith the arm's lensth principle. (4) W'here a taxpayer has used an approved transfer pricing method and the selection of that method is consistent with this regulation, the examination by the Comnrissioner of whether the conditions of the taxpayer's controlled transactions are consistent rvith the arm's length principle shall be based on that transfer pricing method applied by the taxpayer. (5) The following shall be the approved transfer pricing rnethods for purposes of subparagraph (2) _- (a) the Comparable Uncontrolled Price Method, which is the comparable uncontrolled price method consisting of comparing the price charged for property or services transferred in a controlled transaction to the price chargedfor property or services transferued in a comparable uncontrolled transaction: and (b) the Resale Price Method, which is the resale price method consisting of comparing the resale margin that a purchaser of property in a controlled transaction eafils from reselling that property in an uncontrolled transaction with the resale margin that is earned in comparable uncontrolled purchase and resale transactions; and (c) the Cost Plus Method, which is the cost plus method consisting of comparing the mark-,rp on those costs directly and indirectly incurred in the supply of property or ssrvices in a controlled transaction r,vith the mark-up on those costs directly and indirectly incurred in the supply of property or services in a c.omparable uncontrolled transaction; and (d) the Transactional ltiet Margin Method, which is the transactional net margin method c.onsisting of comparing the net prafit margin relative to an appropriate base, such as costs , sales or assets, that a person achieves in a controlled transaction rvith the net profit margin relative to tire same base achieved in comparable uncontrolled transactions; and (e) the Transactional Profit Split Method, w'hich is the of allocatirrg to each associated person participating in a controlled transactional profit split rnethod consisting transaction the portian of common profit (or loss) derived frcrn such transacticn that an independent person r,vould expect to earn from engaging in a comparable uncontrolled 185

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