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.


26 CFR § 1.482-9

Scoping language

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