Tested party.

(i) Tested party. This paragraph (f) applies where the relevant business activity of the tested party as determined under 1.482-5(b)(2) is the rendering of services in a controlled services transaction. Where the tested party determined under 1.482-5(b)(2) is instead the recipient of the controlled services, the rules under this paragraph (f) are not applicable to determine the arm's length result.

Source

26 CFR § 1.482-9


Scoping language

None
Is this correct? or