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Cleaning Up After a Transfer Pricing Adjustment –Collateral Adjustments Can Have a Significant Impact Correlative Adjustments FTC Interaction Rev. Proc. 99-32 Conforming Adjustments Setoff Claims8
Correlative Adjustments A working definition: Following a primary allocation under section482, consistent allocations made with respect to any other member ofthe controlled group affected by the primary allocation. Treas. Reg.§1.482-1(g)(2). Correlative adjustments are recorded in relevant documentationmaintained for U.S. tax purposes E.g., E&P of a controlled foreign corporation Correlative adjustments are mandatory, even if there is no immediateU.S. tax effect Correlative adjustments are triggered only by a final determinationwith respect to a primary adjustment made to one or more controlledparties9
Page 1 and 2: TP Audit Procedures and Adjustments
Page 3 and 4: Burden of Proof - Transfer Pricing
Page 5 and 6: Burden of Proof - Transfer Pricing
Page 7: Burden of Proof - Transfer Pricing
Page 11 and 12: Interaction Between §482 and Forei
Page 13 and 14: Rev. Proc. 99-32 Rules Election to
Page 15 and 16: Simple Example - Rev. Proc. 99-32 D
Page 17 and 18: Transfer Pricing Information - IRS

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