Captive Services Provider Campaign - Transfer Pricing
Read - https://www.irs.gov/businesses/corporations/irs-announces-the-identification-and-selection-of-three-large-business-and-international-compliance-campaigns
On April 16th, the IRS identified 3 additional compliance campaigns
One of them is the Captive Services Provider Campaign
The use of the term “captive” appears to refer generally to controlled, intra-group service providers, and the inclusion of transactions among controlled entities in which a “foreign captive subsidiary performs services exclusively for the parent or other members of the multinational group” on its face potentially could apply to a multitude of intra-group service arrangements, including possibly foreign-to-foreign service arrangements. Until clarifying guidance is issued, the scope of the campaign will not be entirely clear.