Abstract
In spite of the prominent and elaborate treatment accorded the subsections under ss. 1.482-9 and 1.482-4 of the Internal Revenue Code, an in-depth exploration of the above provisions unearth a surprising similarity which if drilled further reveals a bluriness between the two provisions. Thus depending on the method employed in the assessment of arm's length transactions in services as well as transfer of intangibles, the result of establishing transfer pricing sometimes turn out to be the same.
Sign-in/Register to access full text options 
Talk to us
Join us for a 30 min session where you can share your feedback and ask us any queries you have
Schedule a callDisclaimer: All third-party content on this website/platform is and will remain the property of their respective owners and is provided on "as is" basis without any warranties, express or implied. Use of third-party content does not indicate any affiliation, sponsorship with or endorsement by them. Any references to third-party content is to identify the corresponding services and shall be considered fair use under The CopyrightLaw.
