Treasury and the IRS intend to implement the OECD's simplified and streamlined approach (SSA) in its entirety through upcoming proposed regulations.The SSA will serve as a safe harbor for intercompany pricing, providing certainty for routine marketing and distribution activities while minimizing transfer pricing disputes.Taxpayers subject to US tax with respect to in-scope transactions may elect to apply the SSA for tax years beginning on or after January 1, 2025.Treasury and the IRS will continue to consider whether application of the SSA should be mandatory. In Notice 2025-04 (Notice), the Treasury and IRS announced their intent to issue proposed regulations and other...