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.