The comparable uncontrolled transaction (CUT) method is one alternative for determining an arm's-length transfer price for what kind of intercompany transaction?

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The CUT method is commonly used for intercompany transactions involving the licensing of intangible property. This method involves comparing the terms and conditions of the controlled transaction with those of an uncontrolled transaction between unrelated parties to determine an arm's-length transfer price. The method is less commonly used for other types of intercompany transactions, such as the sale of tangible property or the provision of intercompany services.

The Comparable Uncontrolled Transaction (CUT) Method Is One Alternative for Determining