(The Transfer Pricing Examination Process was recently updated by the Department of Treasury - Internal Revenue Service June 2018. TaxConnections is reposting this document in a series to keep you informed of the Transfer Pricing examination process and updates.) D. IRC Section 6662(e) Documentation Request The Initial Transfer Pricing Documentation IDR (formerly known as the Mandatory Transfer Pricing IDR) is no longer required for all cases. Follow the Interim Instructions on Issuance of Mandatory Transfer Pricing IDR in LB&I Examinations. The Senior Revenue Agent/Team Coordinator and the issue team members will collaborate on the issuance of the IDR. It is important to issue the IDR early in the audit process to start working the issue as soon as possible to close the case timely. Please review IRM Exhibit 4.46.3-4 - Transfer Pricing Compliance Processes for specific language: • Treas. Reg. Sec. 1.6662-6(d)(2)(iii) IDR includes a request for principal documents and an index for background documents • Internal Revenue Code Section (IRC Sec.) 6662(e) and Treas. Reg. Sec. 1.6662- 6(d)(2)(iii) require that the taxpayer respond within 30 calendar days. The 30 days starts with the date of the IRC Sec. 6662(e) IDR • The 30 day response time is defined by statute and is an exception to the new IDR and related enforcement processes as described in LB&I Directive on IDR Enforcement Process • The issue team should use this 30 day period to perform analysis of currently available information, which may include prior tax returns and financial statements