Multi-national companies should prepare for more inquiries
Recently the IRS released its Transfer Pricing Audit Roadmap. The guidance provides IRS examiners with audit techniques and tools to assist them in conducting more thorough and consistent transfer pricing examinations.
In the wake of this IRS’s publication, multi-national companies should prepare for more inquiries about their transfer pricing policies and documentation. The audit roadmap puts an emphasis on the review and analysis of IRC § 6662(e) documentation. It will be smart for your company to be prepared should you receive an Information Document Request (IDR) requiring you to submit your transfer pricing documentation within 30 days.
At a minimum, you should have record of your organization’s clear transfer pricing structure. It’s also vital that your international filings (Forms 5471, 5472, 8858, and others) coordinate with the information in your transfer pricing documentation.
Clark Schaefer Hackett professionals have the resources to assess your risks and exposures in this area so you can determine the supporting articles you’ll keep in place. For advisement on this issue, please reach out to your CSH advisor. Our International Services Group stands ready to meet your needs.
