IRS releases transfer pricing audit roadmap

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

IRS releases transfer pricing audit roadmap

The Internal Revenue Service (IRS) has released a roadmap for transfer pricing audit designed as a reference tool for taxpayers involved in typical 24-month audits.

The roadmap describes recommended audit procedures and provides links to useful reference material.

“Every transfer pricing case is unique and requires ongoing exercise of judgment and discretion,” said an IRS press release. “With the release of the roadmap, TPO (Transfer Pricing Operations (TPO) of the Large Business and International (LB&I) division) is providing the public with insight into what to expect during a transfer pricing examination. This transparency is intended to help improve communications and efficiency, for the benefit of both the IRS and taxpayers.”

The TPO will continue to review the roadmap and update it where necessary. Taxpayers are encouraged to contact TPO if they have any recommendations for improvement or feedback.

more across site & shared bottom lb ros

More from across our site

The UK advisory firm has seen its global revenues expand by £27.2m following its listing and acquisition of Baker Tilly South-East Europe
Tax-trained John Sams, previously the firm’s CFO and COO, was appointed after a rigorous process, KPMG said
From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa
ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons
After years of onerous pillar two prep, businesses will be galled in seeing tax revenues outweighed by compliance costs
Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns
Despite the shortfall, effective tax rates of multinationals have seen a ‘statistically significant rise’
After joining Milbank from Akin Gump, the fund tax specialist discusses sponsor demand, practice building, and the tax challenges facing asset managers
Partner payouts could also be reduced by a fifth, it has been reported
There is no logical reason not to extend an exemption from EU CFC rules to multinationals headquartered in side-by-side jurisdictions, USCIB said
Gift this article