In these cases, differences in the figures that comprise the range may be caused by the fact that in general the application of the arm’s length principle only produces an approximation of the conditions that would have been established between independent enterprises.” However, because transfer pricing is not an exact science, there will be also occasions when the application of the most appropriate method or methods produces a range of figures which are relatively equally reliable. “In some cases, it will be possible to apply the arm’s length principle to arrive at a single figure (e.g., price or margin) that is the most reliable to establish whether the conditions of a transaction are arm’s length. In this regard, the 1995 Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (Transfer Pricing Guidelines) of the Organization for Economic Co-operation and Development (OECD) stated in paragraph 1.45 that: Thus, when more than one comparable transaction is available, a range is constructed with the comparable results commonly referred to as the arm’s length range. 37.For the application of transfer pricing methods, it is necessary to make a comparison between the results (prices or margins) of the controlled transaction and the results of comparable transactions (or companies). See later operative version added by Sec. Repealed as of January 1, 2023, by its own provisions.
(b) This section shall remain in effect until January 1, 2023, and as of that date is repealed. (C) Relief shall be available pursuant to subdivision (a) of Section 2924 and Sections 2923.5, 2923.55, 2923.6, 2923.7, 2924.9, 2924.10, 2924.11, and 2924.18 for so long as the property remains occupied by a tenant pursuant to a lease entered in an arm’s length transaction. (iii) A tenant occupying the property is unable to pay rent due to a reduction in income resulting from the novel coronavirus.
(ii) The property is occupied by a tenant pursuant to an applicable lease. (i) The property is owned by an individual who owns no more than three residential real properties, or by one or more individuals who together own no more than three residential real properties, each of which contains no more than four dwelling units. (B) To meet the conditions of this subdivision, a first lien mortgage or deed of trust shall have all of the following characteristics: (iii) “Occupied by a tenant” means that the property is the principal residence of a tenant. (ii) “Arm’s length transaction” means a lease entered into in good faith and for valuable consideration that reflects the fair market value in the open market between informed and willing parties.
(i) “Applicable lease” means a lease entered pursuant to an arm’s length transaction before, and in effect on, March 4, 2020. (2) The first lien mortgage or deed of trust is secured by residential real property that is occupied by a tenant, contains no more than four dwelling units, and meets all of the conditions described in subparagraph (B). (B) For purposes of this paragraph, “owner-occupied” means that the property is the principal residence of the borrower and is security for a loan made for personal, family, or household purposes. (1) (A) The first lien mortgage or deed of trust is secured by owner-occupied residential real property containing no more than four dwelling units. (a) Unless otherwise provided, paragraph (5) of subdivision (a) of Section 2924, and Sections 2923.5, 2923.55, 2923.6, 2923.7, 2924.9, 2924.10, 2924.11, and 2924.18 shall apply only to a first lien mortgage or deed of trust that meets either of the following criteria:
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