The U.S. IRS has published Transfer Pricing Documentation Frequently Asked Questions (FAQs), dated 14 April 2020.
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Treaty and Transfer Pricing Operations
FAQs re Transfer Pricing Documentation Best Practices
A. Transfer Pricing Documentation and Related Penalty Rules
There are three types of penalties described in Internal Revenue Code (IRC) § 6662(e) that may be imposed in the event of a substantial or gross valuation misstatement. One of them—the "net adjustment penalty" descri…