The US IRS on June 29 issued the new guidelines on best practices in transfer pricing examinations, retiring the 2014 Transfer Pricing Audit Roadmap.
The Transfer Pricing Examination Process (TPEP), was issued by the Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division of the IRS.
It is a guide to best practices and processes to assist with the planning, execution, and resolution of transfer pricing examinations consistent with the LB&I Examination Process (LEP), Publication 5125, the IRS said.
The guide note that to more effectively use its resources, LB&I is using data analytics to identify issues for examination that have the most significant risk for non-compliance. It also says that IRS personnel should continually assess the merits of issues during an examination and seek opportunities for issue resolution.
Editor’s note: MNE Tax will be publishing a comprehensive article on this new guidance shortly.
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