21 Jun 2022
Transfer Pricing Penalty and Documentation Best Practices
I.R.C. Section 6662 transfer pricing (TP) penalties generally occur when there is an underpayment of tax attributable to a valuation misstatement, subject to certain thresholds. An understanding of documentation best practices is important because Section 6662(e)(3) imposes a TP penalty only if taxpayers fail to document their TP positions adequately.
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