The AICPA has submitted comments to the IRS regarding proposed regulations that will incorporate the Organisation for Economic Co-operation and Development’s (OECD's) Simplified and Streamlined Approach (SSA) as a new transfer-pricing method under Sec. 482.
The AICPA letter, in response to Notice 2025-04, Application of the Simplified and Streamlined Approach Under Section 482, requests guidance on certain aspects of applying the SSA as described in the OECD’s report on Pillar One Amount B.
The AICPA noted that under Option 1 for applying the SSA, only taxpayers can elect it, while under Option 2 “the IRS could, unintentionally and unnecessarily, compel taxpayers to apply the SSA even when it is neither reliable nor cost optimal.”
The AICPA endorsed Option 1 and recommended that the IRS should withdraw the prioritization of the internal comparable uncontrolled price method as a condition of electing the SSA. See more AICPA recommendations.