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U.S. IRS Practice Unit on Country-by-Country (CbC) Report in the Transfer Pricing Risk Analysis Process

27 April 2022

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Approved Changes

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United States

The U.S. IRS has published a practice unit on the Country-by-Country (CbC) Report in the Transfer Pricing Risk Analysis Process. The process overview of the practice unit includes the following: Globalization has resulted in a shift from country-specific operating models to global models based on matrix management organizations and integrated supply chains that centralize several functions at a regional or global level. Moreover, the growing importance of the service component of the economy, and of digital products and services that often can be delivered over the Internet, has made it much easier for businesses to establish key activities in geographic...