The International Tax Journal published an article by partners Barton Bassett, Anthony Cipriano, Gregory Hartker, Thomas Linguanti, and Tamara Shepard, of counsel Michelle Andrighetto, and associate Drew Cummings about the release of the Internal Revenue Service’s (IRS’s) Notice 2025-04 implementing “Amount B,” the Organization for Economic Co-operation and Development’s (OECD’s) new method for pricing certain baseline intercompany marketing and distribution services.
The article discusses the IRS’s planned implementation of the new transfer pricing method, the challenges of applying the simplified approach to real-world transactions, and the documentation and cross-border coordination issues companies may face.