The Internal Revenue Service (IRS) in the US released the Transfer Pricing Examination Process (TPEP) to be uses in transfer pricing examinations. The TPEP, issued by the Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division, is a guide of best practices and processes to assist with the planning, execution and resolution of transfer pricing examinations consistent with the LB&I Examination Process. With the issuance of TPEP, the Transfer Pricing Roadmap is retired.
The TPEP provides a framework and represents a guide for transfer pricing examinations. Every transfer pricing case is unique and requires ongoing exercise of judgment and discretion. The TPEP guide will be shared with taxpayers at the start of a transfer pricing examination to facilitate an understanding of the process and give insight into what is expected during a transfer pricing examination. This transparency is intended to help improve communications and efficiency, for the benefit of both the IRS and taxpayers. TTPO will continue to review the TPEP and make changes over time as new techniques appear or additional reference materials become available.
The examination procedure includes three phases in total:
With the fast growth of China’s economy and the continuous improvement of the comprehensive strength of domestic enterprises, as well as the implementation of the “One Belt, One Road” policy, an increasing amount of Chinese enterprises are beginning to expand their global footprint and establish their presence in Europe.
TPA Global has developed a practical roadmap of 6 steps meant to guide CFOs in their Journey of rising above troubles to reach a situation of full control. These steps are presented in a series of short video clips (3-5 minutes):