U.S. IRS Issues Notice on Proposed Regulations for Simplified and Streamlined Approach Based on Pillar 1 Amount B

The U.S. IRS has issued Notice 2025-04, announcing that the Department of the Treasury and the IRS intend to issue proposed regulations that, for purposes of applying section 482, provide a new simplified and streamlined approach (SSA) for pricing certain controlled transactions involving baseline marketing and distribution activities. The SSA is based on the OECD Report on Pillar 1 Amount B …
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