Barriers Exist to Properly Evaluating Transfer Pricing Issues

The Commissioner, LB&I Division, should develop a comprehensive transfer pricing strategy that includes outcome-related strategic goals, a description of how the LB&I Division intends to achieve those goals, and an action plan with a timeline for implementation. This strategy should measure the success and productivity of the examinations of transfer pricing issues. This should include, but is not limited to, the amount of the examination adjustments and the taxes ultimately assessed.

The Commissioner, LB&I Division, should implement a postmortem review of examinations with transfer pricing issues that went through the Appeals process. These results should be shared in training efforts to improve the accuracy and quality of future transfer pricing examinations.