IRS to Adopt Simplified Transfer Pricing Rules for Distributors

Prepared by Sophia Castro[1] Jurado and Jack Ortega[2]Introduction Beginning in 2025, the Internal Revenue Service (IRS) plans to introduce the Streamlined and Simplified Approach (SSA) for transfer pricing related to marketing and distribution activities. Modeled after the OECD’s Amount B simplification framework[3], the SSA seeks to standardize and simplify the determination of arm’s-length returns for routine […]