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IRS Issues Final and Temporary Intercompany Services Regulations. The IRS on July 31 issued final and temporary section 482 regulations regarding the treatment of intercompany service transactions and the allocation of income from intangibles. The new regulations, issued principally under new Treas. Reg. §1.482-9T, replace the current 1968-era guidance and contain many changes to address issues raised by taxpayers and commentators following the issuance of proposed regulations in 2003.
Also In this issue:
· IRS Issues Final and Temporary Intercompany Services Regulations
· Turkey Introduces Transfer Pricing Rules in New Corporate Tax Code
· Philippines Set to Enact Transfer Pricing Regulations
· India Triples Threshold for Transfer Pricing Scrutiny
· U.S. IRS Issues Audit Guidelines on Factoring of Receivables
· Profit Shifting in Australia: Should Companies be Worried in 2006?
· Canadian Know-How Royalties and Franchises: A rose by any other name?
· European Council Adopts Transfer Pricing Code of Conduct
· China’s SAT Issues Guidance on Services PEs
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