The Transfer Pricing Examination Process (TPEP), like the Roadmap, will likely continue the trend away from inquisitorial, information-gathering examinations to adversarial, results-oriented discovery aimed at supporting the issue team's pre-established positions.

On June 29, 2018, the IRS released the Transfer Pricing Examination Process (TPEP), replacing the 2014 Transfer Pricing Audit Roadmap (the "Roadmap"). The TPEP largely mirrors the Roadmap, and maintains the Roadmap's three-phase examination process: planning, execution, and resolution. The TPEP specifies that statute extensions should be discussed with taxpayers during the opening conference, and includes sample timelines for 24 and 36 month examinations, so there is no suggestion under the TPEP that transfer pricing audits will conclude any faster than they did under the Roadmap.

 

“US Transfer Pricing Examinations Under the Transfer Pricing Examination Process: The More Things Change, The More They Stay the Same”, published in Journal of International Taxation, April 2019. © 2019 by Thomson Reuters/Tax & Accounting. Reprinted with permission. All rights reserved. This information or any portion thereof may not be copied or disseminated in any form or by any means or stored in an electronic database or retrieval system without the express written consent of Thomson Reuters/Tax & Accounting.

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