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Archive for IRS Transfer Pricing Methodology Review

IRS Charges $113,500 Fee To Review Your Transfer Pricing Methodology Prior To Filing Corporate Tax Return

IRS Charges $113,500 To Review Your Transfer Pricing Methodology

We found this important information on the IRS site…while most multinational corporate tax executives are aware of this fee, there are many company executives who are unaware of the costs of transfer pricing when they hire a transfer pricing consultant. Contact us for referrals to TaxConnections Members who are experts in transfer pricing: https://www.taxconnections.com/contact 

Consider if…
Prior to filing a return, you seek tax certainty and the avoidance of a transfer pricing dispute with the IRS and one or more treaty partner administrations by securing an agreement on a transfer pricing methodology. In an APA, the IRS and one or more foreign tax administrations come to an agreement with the taxpayer on: (1) the factual nature of the inter-company transaction to which the APA applies; (2) an appropriate transfer pricing method (“TPM”) to be applied to any allocation of income, deductions credits or allowances among two or more controlled organizations; and (3) an expected range of results from applying the TPM to the transactions. This program is designed to promptly and fairly resolve APA requests based on principled and cooperative negotiations between the IRS, treaty partner tax administrations, and the taxpayer.

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