Profit level indicators.

(ii) Profit level indicators. In addition to the profit level indicators provided in 1.482-5(b)(4), a profit level indicator that may provide a reliable basis for comparing operating profits of the tested party involved in a controlled services transaction and uncontrolled comparables is the ratio of operating profit to total services costs (as defined in paragraph (j) of this section).

Source

26 CFR § 1.482-9


Scoping language

None
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