Sec. 482 services regulations : implications for multinationals

The authors present an analysis of the Temporary Regulations, issued on 31 July 2006 by the US Treasury Department. They examine the conditions which determine whether there should be a charge for the intercompany provision of services, the services and situations under which the newly introduced services cost method may be used, the various transfer pricing methods provided for valuing the transfer of services and the effect of the Temporary Regulations on the treatment of intangibles.