(Part 1 of Series) – Originally published in TaxConnections The IRS guidance, Transfer Pricing Examination Process, Publication 5300 (TPEP), released in June 2018, is more relevant now than ever before. There is a broad consensus among transfer pricing and international tax practitioners that tax authorities around the globe will step up transfer pricing audit activity … Continue reading
Attention, international tax managers and transfer pricing professionals: The IRS’s Transfer Pricing Examination Process (TPEP) is your insider’s guide to the IRS’s transfer pricing exams. This comprehensive guide, designed for IRS examiners, openly details the inner workings of their process. Learn how to proactively use this knowledge to strengthen your transfer pricing documentation, anticipate IRS inquiries, and avoid costly adjustments. Don’t be caught unprepared. This in-depth analysis of the TPEP will give you a significant advantage in ensuring your company’s transfer pricing practices meet IRS scrutiny. Discover the key takeaways, practical tips, and strategic insights that can make all the difference in the outcome of your next exam. Continue reading
Transfer Pricing NEWS The Transfer Pricing Operations (TPO) of the Large Business and International (LB&I) division of IRS released the 26-page Transfer Pricing Audit Roadmap to the public on February 14, 2014. The Transfer Pricing Audit Roadmap (“Roadmap”) provides audit procedures around an approximate 24-month audit timeline. The stated goals of the roadmap are to assist both … Continue reading
Vietnam’s Ho Chi Minh City tax officials targeting enterprises which reported losses interminably while still expanding business operations December 14, 2012, on the heels of HMRC’s recent interest in Starbucks, Amazon, and Google, Vietnam tax authorities follow suit, investigating Coca-Cola, Adidas, and Metro Cash & Carry for potential causal linkages between transfer pricing and losses in … Continue reading
Irish Revenue announces transfer pricing compliance review (TPCR) guidance On November 26, 2012, the Irish Revenue issued guidance on how they are proposing to monitor transfer pricing compliance in accordance with Part 35A of the Taxes Consolidation Act 1997. A TPCR is a self-review performed by a company of its compliance with Irish transfer pricing legislation. It appears … Continue reading
TRANSFER PRICING INSIGHTS 