Tax Laws & Regulations
This page provides access to key U.S. transfer pricing statutes and regulations under Section 482.
Provides an overview of the transfer pricing regulations issued under Section 482 of the Internal Revenue Code. It outlines the structure of the regulations and summarizes the rules governing the allocation of income, deductions, and credits among related parties.
Establishes the fundamental arm’s length standard, which governs transfer pricing in the United States. This regulation provides general rules for determining whether transactions between related parties reflect results consistent with those that would occur between unrelated parties.
Contains temporary rules supplementing Treas. Reg. §1.482-1. These provisions provide interim guidance on the application of the arm’s length standard and other general principles used in evaluating related-party transactions.
Provides transfer pricing rules for certain specific categories of controlled transactions. These include transactions involving services, loans, and the use of tangible or intangible property between related parties.
Prescribes six specific methods for evaluating the arm's length nature of tangible property transfers: CUP, Resale Price, Cost Plus, Comparable Profits, Profit Split, and Unspecified Methods. It provides detailed guidance on the comparability factors and reliability requirements unique to physical goods.
Provides rules and methods for determining arm’s-length compensation for transfers or licenses of intangible property. The regulation explains valuation approaches and pricing methods used for patents, trademarks, know-how, and other intangibles.
Describes the Comparable Profits Method (CPM), one of the most commonly used transfer pricing methods in practice. The CPM evaluates whether the tested party earns profits consistent with those of comparable independent companies.
Provides guidance on the Profit Split Method, which allocates combined profits from controlled transactions between related parties. This method is often used when both parties contribute valuable intangibles or unique functions.
Sets forth the rules governing Cost Sharing Arrangements (CSAs) between related parties. These rules determine how participants must share development costs and allocate returns associated with intangible property.
Provides illustrative examples demonstrating how the best method rule is applied in transfer pricing analyses. These examples help taxpayers understand how the IRS evaluates competing pricing methods.
Establishes transfer pricing rules for services provided between related parties. The regulation includes several methods, including the Services Cost Method and other approaches for determining arm’s-length service charges.
Provides rules for transfer pricing penalties related to net Section 482 adjustments. These provisions impose accuracy-related penalties when taxpayers substantially misstate transfer pricing results.
Establishes the general accuracy-related penalty applicable to underpayments of tax. The statute includes specific provisions addressing substantial valuation misstatements and transfer pricing adjustments.