Transfer Pricing Tax Fundamentals

Summary

This practice note discusses fundamental issues of transfer pricing. These topics include U.S. transfer pricing rules and regulations, transfer pricing methods, Internal Revenue Service (IRS) and other penalties, documentation requirements and advance pricing agreements (APA). The practice also includes a review of the IRS's APMA program, which provides guidance and information on the administration of APAs. This analysis also covers the amendment process for APAs as a result of the novel coronavirus (COVID-19) pandemic.