United States transfer pricing documentation guide
January 31, 2008
Supplied by TP Week correspondent DLA Piper
The relevant code sections with regard to transfer pricing are internal revenue code sections 482, which deals with the specifics of the arms length standard, along with the penalty provisions of internal revenue code of 6662. Currently, the regulations under 482 address the transfer of tangible property, intangible property, inter-company services and loans and guarantee fees. There are enabling regulations which address definitions and methodologies to document a transfer pricing position.
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