Affirmative Transfer Pricing Adjustments

Summary

This practice note explores how taxpayers use the transfer pricing (TP) rules under Internal Revenue Code (I.R.C.) Section 482 and its accompanying regulations to make affirmative (or taxpayer-initiated) TP adjustments. Generally, a taxpayer can use I.R.C. Section 482 affirmatively in certain circumstances involving an original timely filed tax return (including extensions), an amended return, or a setoff adjustment.