Transfer Pricing Review And Insights The IRS guidance, Transfer Pricing Examination Process, Publication 5300 (TPEP), released in June of 2018, is more relevant now than ever before. There is a broad consensus among transfer pricing and international tax practicioners that tax authorities around the globe will step up transfer pricing audit activity within the next year as a means to recoup lost tax revenue resulting from the pandemic-induced recession. Fortunately, for US-based entities in multinational enterprise (MNE) groups, the IRS has in recent years issued taxpayer guidance on how to prepare for transfer pricing examinations. This series of blog articles is structured to help tax executives quickly get up to speed with the IRS’s guidance on transfer pricing examinations and its expectations on documentation.