Material Intercompany Transactions Template (MITT) submission process for new Compliance Assurance Process (CAP) applicants

Application Material Intercompany Transactions Template (MITT)

A taxpayer applying to the Compliance Assurance Process (CAP) program for the first time must submit an application MITT,  to help determine suitability for the program. Required attachments include transfer pricing studies  for intellectual property and/or financing transactions from the last filed tax year, as well as a current Global Tax Organization Chart (GTOC). 

For example, if the taxpayer applies to the CAP program for the 2027 tax year on Oct. 30, 2026, the taxpayer will complete the MITT using Form 1120 for the tax year ended Dec. 31, 2025, filed on or before Oct. 15, 2026.