IRS Issues Proposed Transfer Pricing Services Regulations

On September 5, 2003, the Internal Revenue Service proposed new transfer pricing regulations (REG-146893-02, REG-115037-00), concerning (i) the provision of services and (ii) the allocation of income attributable to intangible property among commonly controlled entities. These proposals reflect the increasingly international scope of services rendered between affiliates and attempt to bring the existing service regulations, issued in 1968, in line with current practices.