Question
BC, a United States exporter, regularly buys logistics support from FSub, its foreign subsidiary, to ship its products from the United States to overseas markets.
BC, a United States exporter, regularly buys logistics support from FSub, its foreign subsidiary, to ship its products from the United States to overseas markets. FSub occasionally provides transportation services to an unrelated domestic corporation URA. FSub earns 90% revenues from its controlled party BC and 10% from uncontrolled party URA. All the contractual terms of URA with ABC and FSub are the same. You can assume that the controlled and uncontrolled transactions are comparable.
With the given facts, which Transfer Pricing method will you consider as the Best Method for the transaction? Explain any adjustment be needed for accurately comparing the controlled transaction between the uncontrolled transaction between FSub and URA?
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