The Internal Revenue Service is seeking public comments on developing a model memorandum of understanding on transfer pricing issues between national tax authorities.
The IRS said Friday it is specifically seeking comments on bilateral safe harbors with regard to arm’s length compensation for routine distribution functions. These routine distribution functions are frequently an issue in transfer pricing cases.
Last June, the Organization for Economic Cooperation and Development issued a discussion draft on safe harbors, including draft sample memoranda of understanding on certain “low risk” functions. The IRS said it is seeking comments now in recognition that such safe harbors could support sound tax administration.
The IRS is asking for comments that are highly specific to the issues at hand, to the point of proposing text for draft model agreements involving routine distribution functions. The comments should be submitted electronically by May 1 to email@example.com.