The Internal Revenue Service (IRS) has issued Revenue Procedure 2006-9 with updated procedures for obtaining advance pricing agreements (APAs) in transfer pricing cases. APAs give approval from the IRS for the appropriate transfer pricing methodology to be used in cross-border transactions between affiliated companies that are subject to Sec. 482 of the US Internal Revenue Code and the Treasury Regulation thereunder. The text of Revenue Procedure 2006-9 was released on 19 December 2005 and will be published by the IRS on 9 January 2006. It replaces prior Revenue Procedure 2004-40. Revenue Procedure 2006-9 includes a discussion of the principles of...