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Transfer Pricing Documentation

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Junior Member
My question regards federal tax law.


I am student from outside the US, currently working on a comparison of transfer documentation requirements around the globe. I know my questions are quite specific. Nevertheless, I think posting here is worth a trial.

1. Does § 482 IRC also cover permanent establishments? (If so, where do I take this exactly from?)
2. In the § 6662 IRC regulations, mainly all I come about are principal and background documents. I cannot find any further guidance as to what should specifically be included in those documents, e. g. the "business overview". Isn't there any further guidance? Do I have to derive the elements of the documentation (e. g. the functional analysis) only from the substantive rules of § 482 IRC?

Thanks a lot.



Senior Member
26 US Code is the law as written. If you want the IRS' interpretation, you can get it from the publications addressing your particular questions.

You didn't give enough information for me to answer your questions.

Section 482 seems to be aimed at those who would shuffle their money around to avoid taxes, and section 6662 appears to address accuracy penalties.


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