Controlled services transaction
Controlled services transaction(1) In general. A controlled services transaction includes any activity (as defined in paragraph (l)(2) of this section) by one member of a group of controlled taxpayers (the renderer) that results in a benefit (as defined in paragraph (l)(3) of this section) to one or more other members of the controlled group (the recipient(s)).
(1)In general.A controlled services transaction includes any activity (as defined inparagraph (l)(2)of this section) by one member of a group of controlled taxpayers (the renderer) that results in a benefit (as defined inparagraph (l)(3)of this section) to one or more other members of the controlled group (the recipient(s)).