Review of and Insights on the IRS Transfer Pricing Examination Process

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Review of and Insights on the IRS Transfer Pricing Examination Process

WTP Advisors Transfer Pricing specialists Guy Sanschagrin and Doug Schwerdt provide a comprehensive review of the TPEP in the article: “Review of and Insights on the IRS Transfer Pricing Examination Process,” published by Tax Notes International on March 18, 2019. Initially released in June 2018, the TPEP is a 37-page guide prepared by the IRS for its issue teams to help them be better prepared to examine the transfer pricing positions of taxpayers, and it lays out in considerable detail the process and expectations surrounding such an examination. The TPEP replaces the Transfer Pricing Audit Roadmap, issued in 2014.