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U.S. IRS Announces Three Additional Large Business and International Compliance Campaigns

18 April 2019

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Approved Changes

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United States

On 16 April 2019, the IRS Large Business and International (LB&I) Division issued a release announcing the approval of three additional compliance campaigns. The compliance campaigns and their description are as follows: Captive Services Provider Campaign The section 482 regulations and the OECD Transfer Pricing Guidelines provide rules for determining arm's length pricing for transactions between controlled entities, including transactions in which a foreign captive subsidiary performs services exclusively for the parent or other members of the multinational group. The arm's length price is determined by taking into consideration data available on companies performing functions, employing assets, and assuming risks...