The U.S. IRS has published Transfer Pricing Documentation Frequently Asked Questions (FAQs), dated 14 April 2020. --- Treaty and Transfer Pricing Operations FAQs re Transfer Pricing Documentation Best Practices A. Transfer Pricing Documentation and Related Penalty Rules There are three types of penalties described in Internal Revenue Code (IRC) § 6662(e) that may be imposed in the event of a substantial or gross valuation misstatement. One of them—the "net adjustment penalty" described in § 6662(e)(1)(B)(ii)—applies when the net § 482 transfer pricing adjustment exceeds the relevant dollar thresholds. More than one type of penalty under § 6662 may apply to...