Document Type
Article
Publication Date
2025
Abstract
The Internal Revenue Service (IRS) recently issued AM 2025-001, whichrepresents a significant change in its interpretation of the periodic adjustment rules for transfers of intangibles within a multinational and forcost-sharing agreements.Arguably, this finally brings the IRS into compliancewith the “commensurate with income” language added to Code Sec. 482 in1986.
Recommended Citation
Avi-Yonah, Reuven S. "Periodic Adjustments and the Arm's Length Principle." International Tax Journal March-April 2025, no. 2 (2025): 19.
Comments
© 2025 R. S. Avi-Yonah. This article is reprinted with the publisher’s permission from International Tax Journal, a bimonthly journal published by CCH Incorporated. Copying or distribution without the publisher’s permission is prohibited.