(redirected from Comparable Uncontrolled Transaction)
CUTCut Bank (Amtrak station code; Cutbak, MT)
CUTCentral University of Technology (South Africa)
CUTSee You There
CUTCurtin University of Technology (Australia)
CUTCompact Utility Tractor
CUTSee You Tomorrow
CUTCoordinated Universal Time
CUTSee You Then
CUTComing Up Taller (President's Committee on the Arts and the Humanities)
CUTCentral Unitaria de Trabajadores (Spanish: Confederation of Workers; various locations)
CUTCleveland Union Terminal (Cleveland, OH)
CUTCincinnati Union Terminal (railroad station; Cincinnati, OH)
CUTCentral Única dos Trabalhadores (Brazil)
CUTComparable Uncontrolled Transaction
CUTChicago Underground Trio (band)
CUTCodec Under Test
CUTC++ Unit Testing
CUTCircuit Under Test
CUTCaribbean Union of Teachers
CUTChurch Universal and Triumphant
CUTConsumer Use Tax
CUTContinuous Use Temperature
CUTCable Under Test
CUTControl Unit Terminal
CUTConfederated Union of Workers (Costa Rica)
CUTUnited Labor Central (Chile)
CUTUnitary Workers Central (Paraguay)
CUTCampaign for Unmetered Telecommunications (UK)
CUTCentral Utah Telephone
CUTCoding and Unit Testing
CUTCode and Unit Test
CUTCross Utilization Training
CUTConsumer Use Testing
CUTDr Halo Cut Image (file format extension)
CUTCustomer User Test
CUTIntersection of two direction finding bearings
CUTChina United Telecommunications, Ltd
CUTCarcass, Ultrasound, and Tenderness (cattle breeding program)
References in periodicals archive ?
The court found that the CUT method was the correct method to use and that the Pacesetter agreement was a comparable uncontrolled transaction.
Integrated firms arise precisely in order to deviate from arms-length prices in comparable uncontrolled transactions.
The comparable uncontrolled transaction (CUT) method for intangible property transfers is essentially identical to the CUT method for tangible property transfers.
Comparable uncontrollable price method (CUP) Comparable uncontrolled transaction $100.
Application of the Comparable Uncontrolled Transaction Method to the Controlled Transfer of Intangible Property
The comparable uncontrolled transaction might be in a different economic environment, in a different geographic location, or in a location with a different size of market or a different market share.
Rossi explained one reason the safe harbor is helpful is that, in the case of non-integral services, neither the service provider nor recipient is normally in a good position to develop comparable uncontrolled transaction data.
The manual discusses the transfer pricing methods available for the transfer of intangible property: comparable uncontrolled transaction (CUT) and CPM.
This is administratively beneficial for both taxpayers and for tax authorities, because in the case of non-integral services, neither the service provider nor recipient is normally in a good position to develop comparable uncontrolled transaction data.
The Regulations provide for a number of "specified" transfer pricing methods ("TPMs"), including transactional methods such as resale price, cost-plus, comparable uncontrolled price ("CUP"), and comparable uncontrolled transaction ("CUT"), as well as profit-based methods such as the comparable profits method ("CPM") and several profit-split methods.
regulations(5) and, absent a comparable uncontrolled transaction, suggests a consideration of all factors, including prevailing rates in the industry, terms of the license, singularity of the invention, services provided, anticipated profits to be received by the licensee, and benefits to the licensor from sharing information on the experience of the licensee.