Transfer Pricing |
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Section 482 of the Code authorizes the IRS to adjust the income, deductions,credits, or allowances of commonly controlled taxpayers to prevent evasion of taxes or to clearly reflect their income. The regulations under section 482 generally provide that prices charged by one affiliate to another, in an intercompany transaction involving the transfer of goods, services, or intangibles, yield results that are consistent with the results that would have been realized if uncontrolled taxpayers had engaged in the same transaction under the same circumstances.
Transfer Pricing Compliance Directive
Provides information about an important transfer pricing compliance initiative currently underway.
Pacific Association of Tax Aministrators (PATA) Transfer Pricing Documentation Package
This document provides principles under which taxpayers can create uniform transfer pricing documentation (“PATA Documentation Package”) so that one set of documentation can meet their respective transfer pricing documentation provisions.
Advance Pricing Agreement Program
The APA Program provides an alternative dispute resolution mechanism for taxpayers and the IRS to resolve complex international transfer pricing cases.
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Page Last Reviewed or Updated: November 28, 2007