Global Tax Insights
IRS Issues Updated Procedures Regarding Advance Pricing AgreementsOctober 23, 2015
The IRS has recently provided new guidance regarding advance pricing agreements (APAs) which includes changes to user fees and a new transition rule.
The IRS recently issued Revenue Procedure 2015-41 which provides guidance on the process for requesting and obtaining advance pricing agreements (APAs) as well as guidance on the administration of executed APAs.
More about APAs and the new guidance
An APA is an agreement made between a taxpayer and the IRS which specifies what transfer pricing methodology is appropriate for transactions between two or more businesses controlled by the same interests. The new guidance:
- Sets out procedures, rules, and guidelines pertaining to filing an APA request.
- Increases user fees for APA requests.
- Allows a transition rule for requests filed after August 31, 2015.
For more details on the updated APA procedures, read our article, “Advance Pricing Agreements: IRS Issues Updated Procedures”.
Questions? Contact any member of our Global Tax Services Practice.