ArticleIRS Releases Guidance on New Transfer Pricing Methodology
December 19, 2024After years of debate and negotiation, the Organization for Economic Cooperation and Development’s (OECD’s) Pillar One, Amount B has taken a major step forward with the IRS’s release on December 18, 2024, of Notice 2025-04: “Application of the Simplified and Streamlined Approach under Section 482.”