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Adopting a cost-sharing approach will accomplish at least two important goals: (i) the adoption of a transfer pricing methodology providing for a reasonable allocation of centralized services charges to appropriate recipients, and (ii) greater consistency between the U. The IRS National Office has ruled that a company may deduct consulting fees incurred in developing a transfer pricing methodology ( APAs give taxpayers the opprotunity to obtain prior approval of their transfer pricing methodology from the IRS and foreign tax authorities. |
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