Information Document Request for Section 6662(e) Transfer Pricing
Please provide within 30 days of this request any principal documentation outlined in Treas. Reg. Section 1.6662-6(d) (2) (iii) (B) that has been prepared to support your transfer pricing methodologies for all years under examination. This information would generally be provided in the form of a study; however all principal documentation outlined under the Code and associated Treasury Regulation which was prepared for the years under examination, regardless of form, is requested. This documentation should include all internal and/or external studies.
It should be so noted that any documentation prepared by the taxpayer pursuant to Section 6662(e) must be in existence when the return was filed in order to meet the documentation requirement. In addition, if this documentation is not provided within 30 days of this request, and if there are significant adjustments to your transfer price as determined under IRC Section 482, a penalty may be applicable under IRC Section 6662(e) or (h).