N-2025-04: Application of the Simplified and Streamlined Approach under Section 482

Notice 2025-04 announces that the Department of the Treasury and the Internal Revenue Service intend to issue proposed regulations that, for purposes of applying section 482, provide a new simplified and streamlined approach ("SSA") for pricing certain controlled transactions involving baseline marketing and distribution activities. It also provides guidance concerning application of the SSA to in-scope transactions undertaken by parties subject to U.S. tax with respect to those transactions before issuance of those proposed regulations.

Notice 2025-04 will be in IRB: 2025-4, dated January 21, 2025.

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