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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
CUTChina United Telecommunications, Ltd
CUTIntersection of two direction finding bearings
CUTCarcass, Ultrasound, and Tenderness (cattle breeding program)
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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. Like Medtronic's expert, the court started with the Pacesetter agreement royalty rate, made what it considered to be the correct adjustments due to the differences between the Pacesetter and Medtronic US-MPROC license agreements, and converted the rate from retail to wholesale.
Benchmark the comparable uncontrolled transactions against the terms and conditions in use with the European parent and U.S.
Application of the Comparable Uncontrolled Transaction Method to the Controlled Transfer of Intangible Property
In the case of non-integral services, neither the service provider nor recipient is normally in a 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.
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.
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.
[section] 1.482-1T(c)(4)(i) provides that the price for a controlled transfer may be other than the amount charged in a comparable uncontrolled transaction "because the controlled transfer is subject to a pricing strategy that is undertaken to enter new markets, to increase a product's share in an existing market, or to meet competition in an existing market." The controlled transaction must bear a price that would have been charged in an uncontrolled transaction under comparable conditions.
Integrated firms arise precisely in order to deviate from arms-length prices in comparable uncontrolled transactions. (60) Integrated firms can take advantage of economies of scale, organizational efficiencies and saved transaction costs.
In relation to the ex post approach, the Draft proposes to insert the following language in paragraph 3.70 "pricing confirmations should be based on information available at the time the tax return is prepared, providing such information is related to the outcome of comparable uncontrolled transactions undertaken at the same time as the controlled transaction ...." Regrettably, this proposed requirement does not take into account the practical issues involved in updating information on an ex post basis when filing a tax return.