Most appropriate method

The test (sub-rule 1). The most appropriate method is the one best suited to the facts and circumstances of the particular international transaction or specified domestic transaction, and which provides the most reliable measure of an arm's length price.

Factors (sub-rule 2).

• the nature and class of the transaction;
• the class or classes of associated enterprises and the functions they perform, with assets employed and risks assumed;
• the availability, coverage and reliability of data needed for the method;
• the degree of comparability between the transaction and the uncontrolled transaction, and between the enterprises;
• the extent to which reliable and accurate adjustments can be made for differences; and
• the nature, extent and reliability of assumptions needed to apply a method.