AICPA Comments on Notice 2025-04 Application of the Simplified and Streamlined Approach under Section 482

The AICPA sent a letter to both the IRS and Treasury in response to Notice 2025-04 requesting guidance on certain aspects of applying the OECD’s simplified and streamlined approach (SSA) as a new transfer pricing method under the section 482 regulations for pricing of baseline marketing and distribution activities. The SSA is described in the OECD’s report on Pillar One Amount B.