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IRS Seeks Comments on Bilateral Transfer Pricing Safe Harbor: IRS Seeks Public Comments Regarding the Development of a Model Memorandum of Understanding Between U.S. Tax Treaty Partners Outlining Transfer Pricing Safe Harbors for Routine Distribution Services

by James R. Gadwood
Sullivan & Cromwell LLP - New York Office

Donald L. Korb
Sullivan & Cromwell LLP - Washington Office

Alan D. Kravitz
Sullivan & Cromwell LLP - New York Office

Andrew P. Solomon
Sullivan & Cromwell LLP - New York Office

S. Eric Wang
Sullivan & Cromwell LLP - London Office

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.


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