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 new managing director of R&D tax relief consultancy ForrestBrown tells ITR about his priorities for the business, where he’s focusing his time and what makes tax cool
PwC Australia’s response to its tax leaks scandal could give KPMG a useful case study, but so far there’s little sign of positive lessons learned
Tom Goldstein’s attempt to overturn his tax conviction was shot down; in other news, Deloitte promoted several tax partners in Italy
The tax advisory firm becomes the latest member of the Andersen Global network, which has more than 50,000 professionals worldwide
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
Australia’s Department of Finance will also commission an independent review of KPMG’s governance, culture, ethics and integrity frameworks, it has revealed
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
ITR's latest podcast considers how transformational the buyout could be in Ryan's quest for global advisory reach and analyses a recent boom in demand for private client advisory services
The event comes at an important moment for professionals dealing with practical realities related to this practice area
Gift this article