Material Intercompany Transactions Template (MITT) submission process for accepted Compliance Assurance Process (CAP) taxpayers

Accepted Compliance Assurance Process (CAP) taxpayers submit Material Intercompany Transactions Templates (MITTs) according to the schedule below. Submission requirements differ depending on the taxpayer’s phase in the CAP program. Taxpayers in CAP and Compliance Maintenance (CM) phases submit initial, interim (if necessary), and final MITTs. Taxpayers in the Bridge Plus phase submit initial and final MITTs.

Initial MITT

CAP and CM phases

A taxpayer in the CAP or CM phase must submit the initial MITT within 90 days after the end of the prior tax year using information from that tax year. 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). If estimates are necessary because complete information is unavailable, note this on the MITT. The initial MITT is used by the Transfer Pricing Practice (TPP) CAP team to begin the transfer pricing risk assessment for the current CAP year.

For example, a calendar year taxpayer must submit the initial 2026 MITT, as well as all required attachments, using information from the tax year ending Dec. 31, 2026, by March 31, 2027. The TPP CAP team uses this MITT to begin the transfer pricing risk assessment for the 2027 CAP year.

Bridge Plus phase

A taxpayer in the Bridge Plus phase must submit the initial MITT as part of its Bridge Plus documentation package, which is due within four months after the end of the tax year. Required attachments include transfer pricing studies for intellectual property and/or financing transactions from the last filed tax year, as well as a current GTOC. The initial MITT supports the Bridge Plus risk assessment conducted after the close of the tax year. 

For example, a calendar year taxpayer in the Bridge Plus phase for the 2027 tax year must submit the initial MITT, as well as all required attachments, with its Bridge Plus documentation package by April 30, 2028. 

Interim MITT (if necessary)

CAP and CM phases only

A taxpayer in the CAP or CM phase must submit an interim MITT within 30 days after completing a new material transaction or after a material change to a transaction reported on the most recent MITT.

For example, if a material change to a reported transaction occurs on June 9, 2027, the interim MITT reporting that change must be submitted by July 9, 2027. The TPP CAP team uses this MITT to update its transfer pricing risk assessment.

Final MITT

All phases

A taxpayer in the CAP, CM or Bridge Plus phase must submit a final MITT when the prior year tax return is filed. The final MITT is used by the TPP CAP team to conduct its post-filing review for the prior year tax return. For returning CAP taxpayers, it also serves as the equivalent of an application MITT.

For example, if the 2027 tax return is filed on Oct. 16, 2028, the final 2027 MITT based on that return must be submitted on Oct. 16, 2028. The TPP CAP team uses this MITT to complete its post-filing review of the 2027 tax year.