IRC Section 482: Primary U.S. transfer pricing regulation governing intercompany transactions, providing the IRS authority to reallocate income between related parties to prevent tax evasion
IRC Section 6662(e): Specifies accuracy-related penalties for substantial transfer pricing misstatements and documentation requirements
Treasury Regulations ยง1.482-1 through ยง1.482-9: Detailed implementation rules for transfer pricing, including methods, comparability analysis, and specific transaction types
Treasury Regulation ยง1.6662-6: Specific requirements for transfer pricing documentation to avoid penalties
OECD Transfer Pricing Guidelines: International guidelines that influence U.S. transfer pricing practices and provide framework for cross-border transactions
BEPS Action 13: Requirements for transfer pricing documentation including Country-by-Country Reporting, Master file, and Local file
State Transfer Pricing Regulations: State-specific rules and requirements for transfer pricing, including combined reporting and addback provisions
U.S. Customs Regulations: Rules affecting the declared value of imported goods between related parties
Tax Treaties: Bilateral and multilateral agreements affecting transfer pricing treatment between treaty countries
APA Procedures: Guidelines for obtaining Advance Pricing Agreements with tax authorities to prevent future disputes
