Overview Of The IRS Transfer Pricing Roadmap

In February 2014, the Internal Revenue Service (IRS) overhauled its guidance on the conduct of transfer pricing examinations by publishing the Transfer Pricing Roadmap. The Roadmap is aimed at the IRS Large Business and International Division teams that conduct transfer pricing audits, and is intended as a tool for use by those teams. It is organized around a notional 24-month audit timeline and includes recommended audit procedures, along with links to reference materials.

The Roadmap does not represent formal or binding guidance, but it does incorporate various parts of the IRS Internal Revenue Manual, the primary official source of IRS internal guidance to caseworkers. It seems the IRS intends that IRS examiners give the Roadmap a certain weight in conducting transfer pricing audits, and that taxpayers take heed of it.