|March 21, 2013|
Previously published on March 18, 2013
On March 15, 2013, the Internal Revenue Service announced that it is seeking comments from the public regarding the development of a model memorandum of understanding between Competent Authorities relating to transfer pricing safe harbors for routine distribution functions. The IRS’s announcement follows the June 6, 2012, issuance of a discussion draft on transfer pricing safe harbors by the Organisation For Economic Co-operation and Development (the “OECD”). The OECD discussion draft included draft sample memoranda of understanding on a number of “low-risk” functions, including the distribution function.