Arrangements involving tangible property use many methods, and the arrangements involving intangible property (the area currently receiving the most attention) will involve analysis of the Comparable Pricing method (CPM), Profit-Split method (PSM), and the Comparable Uncontrolled Transaction method (CUT).
What does CUT stand for?
CUT stands for Comparable Uncontrolled Transaction
This definition appears very frequently and is found in the following Acronym Finder categories:
- Business, finance, etc.
See other definitions of CUT
We have 56 other meanings of CUT in our Acronym Attic
- Chicago Underground Trio (band)
- China United Telecommunications, Ltd
- Church Universal and Triumphant
- Cincinnati Union Terminal (railroad station; Cincinnati, OH)
- Circuit Under Test
- Cleveland Union Terminal (Cleveland, OH)
- Code and Unit Test
- Coding and Unit Testing
- Coming Up Taller (President's Committee on the Arts and the Humanities)
- Compact Utility Tractor
Samples in periodicals archive:
482-7(g)(2) provides that the arm's-length amount charged in a controlled transfer of intangible property must be determined under one of four methods: * The comparable uncontrolled transaction (CUT) method; * The comparable profits method; * The profit split method; or * Unspecified methods described in Regs.
The comparable uncontrolled transaction (CUT) method is the analog of the CUP method for tangible assets.
The comparable uncontrolled transaction (CUT) method and a revised residual profit split (RPS) method are also included as specified methods.
21) These TPMs largely parallel the methods developed in 1994 for intercompany transfers of tangible and intangible property: ** Comparable uncontrolled services price method (CUSP)--similar to the comparable uncontrolled price (CUP) method for tangible property and the comparable uncontrolled transaction (CUT) method for intangible property.
Exhibit: OECD-recognized TP methods * Comparable uncontrolled price method: Compares the price for properly or services transferred in u controlled transaction to the price charged for property or services transferred in a comparable uncontrolled transaction in comparable circumstances.
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 comparable uncontrolled transaction method (CUT).