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18 December 2024

IRS issues guidance on applying OECD's simplified and streamlined approach to intercompany transactions

The Treasury Department and IRS in Notice 2025-4 announced their intent to issue proposed regulations on implementing a simplified and streamlined approach (SSA) for pricing certain controlled transactions involving baseline marketing and distribution activities between related companies, consistent with the Organisation for Economic Co-operation and Development's 2024 proposal under Pillar One, Amount B. Taxpayers that are subject to US tax with respect to in-scope transactions may elect to apply the SSA for tax years beginning on or after January 1, 2025. A Tax Alert is forthcoming.

Document ID: 2024-2321

 

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