Transcription of TRANSFER PRICING EXAMINATION PROCESS - irs.gov
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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.
2 DEPARTMENT OF TREASURY – INTERNAL REVENUE SERVICE The Transfer Pricing Examination Process provides a guide to best practices and processes to assist with the planning, execution and resolution of transfer pricing
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Action Plan, Base erosion and profit shifting, Background, Taxation Neutralising Base Erosion and Profit, Taxation Neutralising Base Erosion and Profit Shifting, ADDRESSING BASE EROSION AND PROFIT, ADDRESSING BASE EROSION AND PROFIT SHIFTING, DAVIS TAX COMMITTEE, Permanent establishments, Explanatory statement, IFRS Viewpoint, Base Erosion, Notifies the much awaited revised Safe