On 14 February 2014 a Transfer Pricing Audit Roadmap was issued by the Large Business and International (LB&I) division of the IRS. This sets out the procedures in relation to the conduct of a transfer pricing audit and the timeline to follow. The Roadmap is designed to assist tax auditors and taxpayers to resolve issues efficiently and ensure that matters arising can be settled while the audit is taking place, without the need for an appeal procedure. The Roadmap gives taxpayers an insight into the procedures and gives the auditors a work plan. It does not however amount to official guidance but is a working document to be used practically in planning audits.
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US: BEPS to Compound Global Tax Risks
US: BEPS to Compound Global Tax Risks
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