The multilateral regulation for countervailing duties is designed to neutralize the terms-of-trade externalities of a foreign member’s subsidy policy on the importing member’s domestic industry. In trade remedy practice, countervailing duties are used to promote efficient allocation of global resources, and thus the benchmark from a market without government intervention applies in the subsidy calculation. But such a pure market-based benchmark methodology contradicts the intention of the multilateral countervailing regulation and can lead to the conflict of the benchmark rule itself. To solve the problem, the cost or domestic price of the product under investigation can be used as the proper benchmark, which will not only simplify the antidumping and countervailing investigation procedures, but is also logically consistent with the current countervailing duty rules