On 9 September 2021, the United States (US) Internal Revenue Service (IRS) and Treasury released the 2021--22 priority guidance plan, which lists the projects to which the IRS and Treasury will allocate resources for plan year 1 July 2021 through 30 June 2022. This year's plan includes three new transfer pricing-related projects.Two of the new listed transfer pricing projects involve regulations under the Internal Revenue Code1Section 482 transfer pricing provisions on:The effects of group membership on arm's-length pricing (specifically with respect to financial transactions)Clarifying aspects of the arm's-length standard, including "(1) coordination of the best method rule with guidance on...