BDO Transfer Pricing Alert - February 2014
On February 14, 2014, the Internal Revenue Service released the Transfer Pricing Audit Roadmap (the “Roadmap”), which provides an outline for the stages of a transfer pricing audit. The Roadmap is intended for use by international examiners involved in 24-month audits, and states that transfer pricing specialists should be involved prior to the audit’s commencement. The Roadmap is a useful tool for taxpayers, as it indicates the type of information and documents that a taxpayer will be asked to provide in order to support their intercompany transactions, as well as the timeline for which the taxpayer will be expected to do so. The Roadmap emphasizes that fact development is the focus and strength of the Service’s examination teams and even a strong transfer pricing position may not be sustained upon review if the supporting facts are insufficient. The current version of the Roadmap is a work in progress, and the Service encourages users to submit suggestions for improvement.