This past December, the Multistate Tax Commission's (MTC)
transfer pricing advisory committee and its project facilitator Dan
Bucks recommended what it calls the "preliminary design"
approach for a proposed Arm's Length Adjustment Services (ALAS)
program. While still subject to approval, states have already
put designs on increasing state transfer pricing revenues.
The MTC ALAS is an attempt to bring to state governments a
comprehensive and coordinated program to address income shifting
and the loss of state tax revenues, much along the lines of what
the United States and other foreign governments have been trying to
do, most recently in their Base Erosion and Profit Shifting (BEPS)
initiative. The MTC program is intended to address both
interstate income shifting, which is never addressed at the federal
level, and international income shifting, which the MTC believes is
massively under-audited at the federal level. According to
some estimates, state revenue losses
