SECTION 4. APPLICATION

The services cost method (SCM) as set forth in Temp. Treas. Reg. § 1.482–9T(b) evaluates whether the price for covered services, as defined, is arm’s length by reference to the total services costs with no markup. Two categories of covered services are eligible for the SCM. The first category, specified covered services, is described in Temp. Treas. Reg.

§ 1.482–9T(b)(i) and is limited to services that are described in this revenue procedure. The second category, low margin covered services, is not described in this revenue procedure.