Access Leading Tax Experts And Technology
In Our Global Digital Marketplace

Please enter your input in search

What To Expect When You Are Expecting A Transfer Pricing Examination

What To Expect When You Are Expecting A Transfer Pricing Examination

Transfer pricing examinations can be unpleasant experiences for taxpayers. Chances are, an international business in the U.S. – whether it is headquartered in the U.S., or a subsidiary of a foreign parent – is going to have its transfer pricing examined by the IRS or another tax authority.

Transfer pricing has been cited by IRS officials for years as one of their most important enforcement priorities. But as a direct result of BEPS (the OECD’s Base Erosion Profit Shifting project), tax authorities around the world are actively engaged in the process of revising and tightening their expectations and requirements with respect to transfer pricing. The prospect of thorough and detailed examinations of taxpayers’ transfer pricing positions is growing every day.

Fortunately for multinational companies operating in the U.S., an important document exists that can help taxpayers be better prepared for the eventual IRS transfer pricing exam: The Transfer Pricing Examination Process, Publication 5300 (TPEP). Originally released in June 2018, the TPEP is a 37-page guide prepared by the IRS for its issue teams to help them be better prepared to examine the transfer pricing positions of taxpayers, and it lays out in considerable detail the process and expectations surrounding such an examination. The TPEP replaces the Transfer Pricing Audit Roadmap, which was issued in 2014. WTP Advisors’ Guy Sanschagrin and Doug Schwerdt authored a comprehensive review of the TPEP, “Review of and Insights on the IRS Transfer Pricing Examination”, which was published by Tax Notes International on March 18, 2019. This article contains key insights to help taxpayers be better prepared and it can be accessed by clicking here.

Guy Sanschagrin And Doug Schwerdt

Guy Sanschagrin

Over twenty years of experience developing and implementing high-value profit and cash flow enhancement solutions in the areas of transfer pricing, valuation, business process improvement and economics consulting. Frequent speaker at seminars and webinars and have written articles for many publications including being named by Euromoney / Legal Media as one of the leading and most respected transfer pricing advisors in the world.

Our results-oriented practice puts our client’s needs first to enable them to achieve their transfer pricing and valuation objectives efficiently and cost effectively. We offer a practical and flexible approach by combining our technical experience with creative problem solving and personalized service. We collaborate with our clients to identify, evaluate and address risks and opportunities, streamline processes, manage data, optimize resource allocation, address specific project needs and develop in-house capabilities. Our specific areas of expertise include transfer pricing, valuation, cost sharing, process improvement, supply chain management and international business management.

Twitter LinkedIn 

Subscribe to TaxConnections Blog

Enter your email address to subscribe to this blog and receive notifications of new posts by email.


One thought on “What To Expect When You Are Expecting A Transfer Pricing Examination

  1. Avatar Kat Jennings says:

    The Transfer Pricing Software you and your team built at is so impressive I have been telling corporate tax executives they will want it. It was built by your team of former Big Four tax experts who had to deal with previous software that was a challenge to understand. Your development team has done an amazing job.

    After touring software for corporate transfer pricing and international tax, I was impressed and so are corporate tax executives: Take the tour at

Comments are closed.