Editing Transfer pricing (section)

====Best method rule====
Some systems give preference to a specific method of testing prices.  OECD and U.S. systems, however, provide that the method used to test the appropriateness of related party prices should be that method that produces the most reliable measure of arm's length results.<ref>OECD Guidelines 1.68-1.70, 26 CFR 1.482-1(c), [http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div8&view=text&node=26:6.0.1.1.1.0.8.189&idno=26 26 CFR 1.482-8].</ref>  This is often known as a "best method" rule.  Factors to be considered include comparability of tested and independent items, reliability of available data and assumptions under the method, and validation of the results of the method by other methods.