Monday, February 17, 2014
The IRS on Friday released Transfer Pricing Audit Roadmap:
In recognition of the strategic importance of transfer pricing, LB&I has established a dedicated team of transfer pricing specialists (Transfer Pricing Operations or TPO) headed by an executive and encompassing both the Advance Pricing and Mutual Agreement Program (APMA) and the Transfer Pricing Practice (TPP). This team has developed this Transfer Pricing Audit Roadmap (Roadmap) to provide the transfer pricing practitioner, 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 Roadmap is a practical, user-friendly toolkit that is organized around a basic audit time-line and that provides advice and links to useful reference material. It is not intended as a template – every transfer pricing case is unique, and the team will need to exercise its own judgment about how to best use these guidelines. The Roadmap is a “work in process” – users are strongly encouraged to contact the Income Shifting Issue Practice Networks (IPN) with any corrections, proposed additions or deletions, or other suggestions for improvement.
The following paragraphs summarize some of the key themes that run through the Roadmap and that should be kept in mind by the exam team in any transfer pricing case.