In addition to using its transfer pricing software, we have engaged transfer pricing expert, Dr.
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The closing agreement will determine timing of payment.
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How long does each side have to pay a refund/remit additional tax due at the end of a resolution?.Non-transfer pricing items will be reviewed according to normal audit or request for review procedures. What is the extent of the review of the intercompany transactions?įor participants in the program, we intend to review intercompany transactions per the standard procedure, including any relevant reciprocal adjustments.After the Division makes its proposal, will back and forth negotiations be allowed within the 30-day window?.Will an administrative look-back period be applied?įor cases under audit, the years will be limited to those under review, including any future years subject to a closing agreement.The rules of voluntary disclosure will apply to non-filing affiliates that qualify under the voluntary disclosure program. How will non-filing affiliates to the intercompany transaction be looked at or handled?.A taxpayer may participate in as many years as they choose. Does a taxpayer have to participate in all open years?.Issues beyond those contemplated in the initiative will still be permitted to be protested under normal statutory provisions. If we do not reach an agreement, the taxpayer's statutory rights to appeal will not be affected in any way by the initiative. Are rights to appeal being impacted by this initiative?Īny closing agreement we reach with a taxpayer through the initiative process will require the taxpayer to waive its right to appeal.However, we do not intend to grant abatement of penalties. Taxpayers that elect not to participate in the initiative may still request a waiver of penalties. Can a taxpayer currently under audit, who does not participate in the initiative, be allowed to request a waiver of penalties?.If the taxpayer elects to participate while in audit, and no agreement is reached, the audit process will resume under normal audit procedures. If a taxpayer is currently under audit and elects to participate in the initiative, but theĭivision and the taxpayer do not come to an agreement, does the case just return to audit without further opportunity to settle or waive penalties?.If no agreement is reached with CAB, existing statutory procedures (e.g., issuance of a Notice of Final Determination) will apply. If no agreement is reached with the Audit Branch, the matter can still be considered by CAB. If a taxpayer has a case with the Conference and Appeals Branch (CAB), participates in the initiative, and the taxpayer and the Division do not come to an agreement for this initiative, what happens next?.
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Taxpayers should request that the case be remanded to the Audit Branch for reconsideration under the initiative. Yes, taxpayers in the CAB process may participate.