Transcription of TRANSFER PRICING EXAMINATION PROCESS
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TRANSFER PRICING EXAMINATION PROCESS
TRANSFER PRICING EXAMINATION PROCESS Publication 5300 (5-29-2019) Catalog Number 71492Y Department of the Treasury Internal Revenue Service DEPARTMENT OF TREASURY INTERNAL REVENUE SERVICE Revised June 6, 2019 2 The TRANSFER PRICING EXAMINATION PROCESS (TPEP) provides a guide to best practices and processes to assist with the planning, execution, and resolution of TRANSFER PRICING examinations consistent with the Large Business & International (LB&I) EXAMINATION PROCESS (LEP), Publication 5125. This guide will be shared with taxpayers at the start of a TRANSFER PRICING EXAMINATION , so they understand the PROCESS and can work effectively with the EXAMINATION team.
5 PLANNING PHASE I. Planning Phase This phase of the examination process determines the scope of the audit. Issues selected for examination should have the broadest impact on achieving compliance
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