Rule 78 defines the "other method" of determining arm's length price under section 165(1)(f): any method that takes into account the price charged or paid, or that would be charged or paid, in the same or a similar uncontrolled transaction between non-associated enterprises in similar circumstances.
78
Rules 2026 · Rule 78
Other method for determination of arm's length price
Rules 77-130
The rule. For section 165(1)(f), the other method for an international transaction or a specified domestic transaction is any method that takes into account the price which (a) has been charged or paid, or (b) would have been charged or paid, for the same or similar uncontrolled transaction, with or between non-associated enterprises, under similar circumstances, considering all the relevant facts.
Where it fits. It is the sixth method in rule 79(1)(f), after the five specified methods.