The IRS Large Business & International (LB&I) division has released a transfer pricing audit “roadmap” that is intended to be a practical, user-friendly toolkit organized around a notional 24-month audit time-line.
The roadmap has been issued in recognition of the strategic importance of transfer pricing. A dedicated team of transfer pricing specialists (known as “Transfer Pricing Operations” or TPO) has been established within the tax administration and includes both the Advance Pricing and Mutual Agreement Program (APMA) and the Transfer Pricing Practice (TPP).
The Transfer Pricing Operations team has developed the transfer pricing audit roadmap to provide transfer pricing practitioners, whether employed in TPO or International Business Compliance (IBC), with audit techniques and tools to assist with the planning, execution, and resolution of transfer pricing examinations. The transfer pricing audit roadmap is described as a practical, user-friendly toolkit, organized around a basic audit time-line and provides advice and links to useful reference material.
The audit roadmap is not intended as a template, and notes that every transfer pricing case is unique. The team is expected to exercise its own judgment about how to best use these guidelines.
