IRS releases its ‘roadmap’ of the transfer pricing audit process
By Sirathorn BJ Dechsakulthorn, Paul Flignor and Eric D Ryan
The US Internal Revenue Service has released its Transfer Pricing Audit Roadmap, a 26-page outline of the two-year transfer pricing audit process, emphasising upfront planning and a fact-based approach for examiners.
The roadmap, released on 14 February, is part of an ongoing effort by the IRS Large Business and International Division to standardise the exam process. The stated goal of the roadmap is to assist both the IRS and taxpayer in the identification, selection, discussion and resolution of potential transfer pricing issues in a timely and orderly fashion and to resolve issues at the exam level rather than at appeals.
The roadmap emphasises the fact-based nature of transfer pricing audits, that ‘transfer pricing cases are usually won and lost on the facts’. It asserts that the facts should support a ‘working hypothesis’ on the reasonableness of the inter-company pricing policies that discourages fishing expeditions. Lastly, the roadmap stresses the importance of an effective presentation that integrates facts and legal and economic principles into a compelling story…
Click on the link below to read the rest of the DLA Piper briefing.
Sign in or Register to continue reading this article
It's quick, easy and free!
It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.Register now
Why register to The Lawyer
In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.
Identify the major players and business opportunities within a particular region through our series of free, special reports.
Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.
More relevant to you
To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.
News from DLA Piper
News from The Lawyer
Briefings from DLA Piper
The Australian Taxation Office released a draft ruling on the Goods and Services Tax treatment of bitcoin transactions on 20 August 2014.
DLA Piper’s ‘Life sciences: patent extension strategies and antitrust global update’ video covers global antitrust and competition issues including product hopping and reverse payment patents.
Analysis from The Lawyer
Still the lawyer’s destination of choice in the region, despite falling oil prices
Cross-border work and political tensions are dominating this year’s entries for Finance Team of the Year at The Lawyer Awards.