If you apply for or participate in an independent review, you still retain your full dispute and statutory objection rights.
You will also retain these rights if you are not eligible for an independent review, or if you choose not to seek an independent review. You are also still able to consider all your options for resolving disputes.
While the majority of transfer pricing cases are ineligible for an independent review, we are committed to resolving transfer pricing disputes early. We will continue to work with you to narrow or resolve disputes.
Our public guidance such as Practical Compliance Guidelines, can help you to document and determine your related party pricing. Our guidance is developed by subject matter experts and seeks to limit areas of dispute.Outlines the criteria for a large market independent review (LMIR) of a Statement of audit position paper.