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ARTICLE · 22 FEBRUARY 2018

Transfer Pricing Times: IRS Issues New LB&I Directives

On January 12, 2018, the U.S. IRS Large Business and International ("LB&I") Division issued several new directives establishing procedural changes aimed at enabling the IRS to manage resources in transfer pricing audits.

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In this edition: the U.S. Internal Revenue Service Large Business and International division issued several new directives establishing procedural changes; the OECD launched the International Compliance Assurance Program; the U.S. Tax Cuts and Jobs Act has several provisions that will have an impact on the practice of transfer pricing; the Taiwan Ministry of Finance announced amendments to the Assessment Rules for Non-Arm's Length Transfer Pricing of Profit-Seeking Enterprise; Australia released guidance documents on diverted profits tax and issued finalized risk framework for evaluating intercompany loans; and Spanish tax authorities announced the Tax Control Plan for FY2018. 

IRS ISSUES NEW LB&I DIRECTIVES

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