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.