AICPA comments on proposed regs. on new transfer-pricing method

The comments are in response to Notice 2025-04, which announced plans for the simplified and streamlined approach as a new transfer-pricing method under Sec. 482 regulations for pricing of baseline marketing and distribution activities.

Transfer pricing: The C-suite needs to be informed

CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous amounts at stake in tax disputes, financial reporting risk from uncertain tax positions, and customs valuations.

Pillar Two and nonprofit organizations

Although the Organisation for Economic Co-operation and Development’s Inclusive Framework on Base Erosion and Profit Shifting excludes nonprofit organizations, they may be subject to the rules if a subsidiary or group member engages in a trade or business.

Taxpayer-initiated transfer pricing adjustments in MAP

When multinational enterprises proactively initiate transfer pricing adjustments to avoid penalties or for other reasons, a tax treaty’s mutual agreement procedure (MAP) can help prevent double taxation, but additional issues should be considered.