TRANSFER PRICING QUESTION: (Has to do with the specified transfer pricing methods)

Explain for each specified method how each of the following impact the Arms Length Standard: 1. Substance over form; 2. Multi-year data; 3. Interquartile range. For each of the above include the Treasury Regulation section reference and definition when you provide your answer. (Some of the methods are similar, so please aggregate the response where appropriate)

Specified Methods:

Tangible: Comparable Uncontrolled Price (CUP)

Resale Price Method (RPM)

Cost-Plus Method (C+)

Profit Split Method (PSM)

Comparable Profits Method (CPM)

Intangible: Comparable Uncontrolled Transaction (CUT)

Profit Split Method (PSM)

Comparable Profits Method (CPM)

Services: Comparable Uncontrolled Services Price (CUSP)

Services Cost Method (SCM)

Gross Services Margin Method (GSMM)

Cost of Services Plus Method (COSP)

Profit Split Method (PSM)

Comparable Profits Method (CPM)