The IRS continues to review and update the Transfer Pricing
Examination Process ("TPEP"), taking into account
revisions to the Internal Revenue Manual regarding the development
of IRC 482 cases and routine feedback from examiners, taxpayers,
practitioners, and other stakeholders. The TPEP, initially released
on June 18, 2018, provides a framework and guide for transfer
pricing examinations, including their planning, execution and
resolution.
Although updates have not materially changed the core content of
the TPEP as originally issued, they do serve to highlight the
ongoing commitment of the IRS to the TPEP and the best practices
and processes it provides. Taxpayers are reminded that the TPEP not
only contains guidance in relation to the examination of transfer
pricing issues but also in relation to the selection of issues.
