Last summer the Organization for Economic Cooperation and Developmentissued a draft discussing safe harbors that included draft content surrounding "low risk" functions. Now, the IRS seeks public response to help develop a better understanding of transfer pricing issues between national tax authorities.
Specifically, the IRS is interested in comments on bilateral safe harbors with regard to arm's length compensation for routine distribution functions which are frequently an issue in transfer pricing cases.
Source: Accounting Today
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The IRS is asking for comments that are highly specific to the issues at hand, to the point of proposing text for draft model agreements involving routine distribution functions. The comments should be submitted electronically by May 1 to lbi.apmacomments@irs.gov.