According to a Tax Analysts article dated 3 February 2021, the United States (US) Department of the Treasury (Treasury) may soon open a project to revive transfer pricing aggregation regulations under Internal Revenue Code1 Section 482 that were issued in temporary form in 2015 but expired in 2018 without being finalized.BackgroundIn July 1994, the Treasury published final transfer pricing regulations under Treas. Reg. Section 1.482-1, which included a set of rules on the aggregation of interrelated transactions in determining arm’s-length transfer pricing. The relevant portion of the regulation states:The combined effect of two or more separate transactions (whether before, during, or after...