U.S. IRS Publishes Practice Unit on Arm's Length Determination for Transfers of Intangibles Property and CSAs

On 4 January 2017, the U.S. IRS published an international practice unit entitled IRC 367(d) Transactions in Conjunction with Cost Sharing Arrangements (CSA). The practice unit covers requirements in relation to the practice of transferring high value intangibles to a related party located in low-tax jurisdictions. In particular, the practice unit looks at the determination and potential aggregation of:

• The arm's length income (charge) required for the use of intangible property transferred…