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IRS updates section 482

August 12, 2009

New service regulations from the Internal Revenue Service are not expected to bring a significant effect to transfer pricing in the US.

The service regulations, which cover section 482 of the Internal Revenue Code, address the treatment of controlled services transactions and the allocation of income from intangible property, in particular with respect to contributions by a controlled party to the value of intangible property owned by another controlled party.

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