【正文】 er the first fact pattern, one would ordinarily apply the cost plus method, and under the second, the resale price method. As indicated above, the gross services margin method generally applies when the services at issue are intermediary in nature and the cost of services plus method applies when the tested party renders the same services to both affiliated and independent panies. Under the fifth and sixth fact patterns, one’s choice between the resale price and cost plus methods would be dictated by each group member’s ownership of intellectual property and the relative values thereof. Under the last fact pattern, the choice of methods depends on whether the licensee is a manufacturer or a distributor. The . regulations impose higher standards of parability under the resale price and cost plus methods, as pared to the CPM: Products must be “of the same general type (., consumer electronics),”11 and the parties being pared should perform similar functions, bear similar risks and operate under similar contractual terms. As previously noted, the OECD Guidelines do not differentiate between transfer pricing methods in establishing parability criteria to the same degree as the . regulations. Such criteria include the character of the property or service, the functions performed by the parties, contractual terms, economic circumstances and business strategies. Description of Resale Price and Cost plus Methods Briefly stated, under the resale price method, one pares the captive distributor’s gross margin on product sourced from affiliated panies with its gross margin on product sourced from unaffiliated panies. If the captive distributor does not source similar products from both affiliated and unaffiliated panies, one can pare its resale margin on products sourced from affiliated suppliers with the resale margins reported by unaffiliated distributors that source similar products from independent suppliers. An analogous parison is made under the cost plus method and the cost of services plus method, except that the profit level indicator differs. More particularly, under the cost plus and cost of services plus methods, the profit level indicator is equal to gross profits divided by cost of goods (or services) sold. Underlying Economic Rationale Less than one interpretation, the resale price method, applied to internal transactions, presupposes that individual distributors would pay similar purchase prices to their multiple suppliers on an arm’s length basis and charge their unrelated customers similar selling prices. This set of assumptions, in turn, implies that (a) suppliers operate in the same petitive market or have no binding capacity constraints and value the subject distributor’s business relatively highly, and (b) the distributor cannot (and is not forced to) differentiate among its customers in establishing its selling prices. If the resale price method depends on these assumptions for its validity, gross margin parisons would only be valid if the products generating such margins are quite similar, not simply of the “same general type”. Similarly, the cost plus method, applied to internal transactions, may presuppose that individual manufacturers are unable to differentiate among customers in establishing their selling prices, and employ the same or similar technologies in producing product for different customers. Again, under this rationale, the products on which markups are being pared must be closely similar. Alternatively, the economic rationale for internal paris