Transfer Pricing Issues Top IRS’s Latest Priority Guidance Plan

Transfer pricing issues affecting cross-border taxation took center stage in the Internal Revenue Service (IRS) and Treasury’s 2021-2022 Priority Guidance Plan (Plan). The Plan identifies and prioritizes tax issues the IRS and Treasury will address via revenue rulings, revenue procedures, notices, and other published administrative guidance. One of the Plan’s priorities involves updating guidance regarding the procedures for requesting and obtaining advance pricing agreements (APAs) and the execution of APAs. As APAs generally involve one or more taxpayers and one or more tax authorities, it’s important to consult international guides that address essential aspects of transfer pricing law and policy.

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