【正文】 rating of the borrower and the loan terms. The . transfer pricing regime also enpasses intrafirm “costsharing” and “global dealing” as special cases, addressed in separate provisions. Costsharing regulations govern circumstances in which related panies jointly contribute to research and development activities, and are assigned specific, nonoverlapping ownership rights in the research results. The term “global dealing operation” refers to multinational financial intermediaries that buy and sell financial products, manage risk and execute transactions on behalf of customers. The proposed global dealing regulations do not formally enpass the global trading of physical modities (as distinct from financial products), although “the IRS solicits ments on whether these regulations should be extended to cover dealers in modities . . .” Resale Price and Cost Plus methods Consider next the resale price and cost plus methods. Both are transactionsbased methods that the OECD favors over the CPM/TNMM. Circumstances when Resale Price and Cost Plus methods Apply The resale price and cost plus methods (and, under the . Temporary Regulations, the gross services margin method and the cost of services plus method) can be applied under the following fact patterns: 1. A single manufacturer sells similar products to both affiliated and unaffiliated distributors。 3. A single services provider renders similar liaison or agency services (in the case of the gross services margin method) to both affiliated and unaffiliated panies, and, if relevant, utilizes the same intangible assets in doing so。 5. Two or more manufacturers sell similar products, in one instance to affiliated distributors, and in the other instances, to unaffiliated distributors。 and 7. A group member performs routine manufacturing or distribution functions and licenses intellectual property from another group member. Given one of the above fact patterns, one’s choice between the resale price and cost plus methods depends principally on whether (a) one of the group members engages in internal arm’s length transactions, and (b) the affiliated manufacturer or the affiliated distributor is the least plex entity (and therefore, the designated tested party). For example, under 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 fun