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Clarification of the Coordination of the Transfer Pricing Rules With Other Code Provisions

tax-irs · IRS · Rule · Published 2015-09-16 · Effective 2015-09-14 · 80 FR 55538

Document

Document number
2015-23278
Federal Register citation
80 FR 55538
CFR reference
26 CFR 1
Type
Rule
Action
Final and temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2015-09-16
Effective date
2015-09-14
Treasury docket
TD 9738

Abstract

This document contains temporary regulations that clarify the coordination of the application of the arm's length standard and the best method rule under section 482 of the Internal Revenue Code (Code) in conjunction with other provisions of the Code. The text of the temporary regulations also serves in part as the text of the proposed regulations (REG-139483-13) published in the Proposed Rules section of this issue of the Federal Register. This document also contains final regulations that add cross-references in the existing final regulations under section 482 to relevant sections of these temporary regulations.

Source

Authoritative
Federal Register document
Machine
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