SPECIAL REPORT: Internal Tensions Hindering IRS Transfer Pricing Goals

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A little more than two years after the launch of the Internal Revenue Service's Transfer Pricing Operations unit, the agency's effort to strengthen its hand in high-profile international cases hasn't played out as its architects planned, practitioners say.

While it is still too early to gauge the full impact of the TPO, several practitioners told Bloomberg BNA that, in practice, its launch has led to confusion, internal conflicts and inconsistency in the field.
The best practices set out in the transfer pricing audit “road map” aren't always followed, they said. Furthermore, there is uncertainty about lines of authority, and audits often bog down amid tensions between domestic examiners eager to close out cases and international examiners pushing to keep them open.