Transcription of TRANSFER PRICING EXAMINATION PROCESS - irs.gov
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TRANSFER PRICING EXAMINATION PROCESS - irs.gov
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. TRANSFER PRICING examinations are factually intensive and require a thorough analysis of functions performed, assets employed, and risks assumed along with an accurate understanding of relevant financial information.
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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