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Tag Archive for Transfer Pricing Audit Roadmap

Large Business And International Transfer Pricing Audit Roadmap

The Transfer Pricing Operations (TPO) of the Large Business and International (LB&I) division of IRS has released the Transfer Pricing Audit Roadmap to the public.  The Transfer Pricing Audit Roadmap (Roadmap) is a practical, user-friendly toolkit organized around a notional 24 month audit time-line.

The Roadmap provides recommended audit procedures and links to useful reference material. It is not intended as a template. Every transfer pricing case is unique and requires ongoing exercise of judgment and discretion.  With the release of the Roadmap, TPO is providing the public with insight into what to expect during a transfer pricing examination.  This transparency is intended to help improve communications and efficiency, for the benefit of both the IRS and taxpayers.

The Roadmap is a “living document”. TPO will continue to review the Roadmap and make changes over time as new techniques arise or additional reference materials become available.  Users are encouraged to contact the TPO to provide any input, feedback and suggestions for improvement.

As Reported By The IRS:

https://www.irs.gov/pub/irs-utl/FinalTrfPrcRoadMap.pdf  

 

 

IRS Releases Transfer Pricing Audit Roadmap

Transfer pricing audit is getting a momentum and is being perceived as a big weapon in the hands of the Internal Revenue Service for the adjustments. IRC 482 gives immense powers to the IRS for adjusting income, credits and deductions of a taxpayer where it finds that a revenue is lost due to the related party transactions that were not conducted on arm’s length standard.

The IRS’s Large Business and International division has released a roadmap providing detailed guidance on transfer audits, including audit techniques and tools to assist with transfer pricing exams, as well as an estimated timeline for the exam, insights as to how the exams will be conducted, and tips for upfront planning. Read more

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