Global

Details

  • Service: Tax, Global Transfer Pricing Services
  • Type: Regulatory update
  • Date: 2/16/2014

United States - IRS releases transfer pricing audit “roadmap” 

February 16:  The IRS Large Business & International (LB&I) division released a transfer pricing audit "roadmap" intended to be a practical, user-friendly toolkit organized around a notional 24-month audit time-line.

The IRS transfer pricing audit roadmap [PDF 379 KB]:


  • Is issued in recognition of the strategic importance of transfer pricing
  • Reflects that a dedicated team of transfer pricing specialists (known as "Transfer Pricing Operations" or TPO) has been established and includes both the Advance Pricing and Mutual Agreement Program (APMA) and the Transfer Pricing Practice (TPP)
  • States that the Transfer Pricing Operations team developed the transfer pricing audit roadmap to provide the transfer pricing practitioner, whether employed in TPO or International Business Compliance (IBC), with audit techniques and tools to assist with the planning, execution, and resolution of transfer pricing examinations

The transfer pricing audit roadmap is described as a practical, user-friendly toolkit, organized around a basic audit time-line and provides advice and links to useful reference material.


The transfer pricing audit roadmap is not intended as a template, and notes that every transfer pricing case is unique, pointing out that the team will need to exercise its own judgment about how to best use these guidelines.


The IRS describes the transfer pricing audit roadmap as a “work in process.”


Text of the roadmap is also posted on an IRS webpage.



Contact a tax professional with KPMG's Global Transfer Pricing Services.




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