November 16, 2022

An In-Depth Look at the Quagmire of Transfer Pricing Audits


Transfer pricing audits remain a challenge for taxpayers and the IRS. IDRs that sometimes feel like discovery requests. Interviews that seem more akin to depositions. Audits that can seem never-ending, despite thoughtful discussions about the audit timelines. Join Mayer Brown and Economics Partners for a two-part series—an in-depth look at the current state of transfer pricing audits.

In Part One, we’ll discuss what taxpayers can do to better prepare for a future audit, how to manage a current audit more effectively, and what to expect at the end of an audit. Join us as we discuss documentation, IDRs, interviews, penalties, and more. We’ll spend time talking about the practical implications of recent cases including, for example, the IDRs that ask whether the intercompany agreements reflect reality and detailed questions about system profits-type data. We plan to spend 60 minutes in discussion and then will open the conversation up to the audience for questions for the remaining time. We welcome your questions in advance of the webinar as well.

In Part Two, we’ll discuss options to resolve transfer pricing audits (IRS Appeals or MAP) and ways to avoid them in the first instance with APAs or ICAP. We’ll talk about strategies to reach the best resolution as early as possible and then what happens when these options fail and litigation becomes the only path to resolution. Part Two of our conversation will be in February, and an invitation will be sent a month in advance.

Speakers from Economic Partners:

Perry Urken

Brian Vincent


For additional information or to register, please contact Shilpa Patel at or +1 312 701 8487.

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