jueves, 12 de mayo de 2016

US 2015 APA report shows large uptick in requests before new rules took effect

The IRS Advance Pricing and Mutual Agreement Program (APMA) on March 31 issued its 17th Annual Statutory Report concerning Advance Pricing Agreements (APAs), Announcement and Report Concerning Advance Pricing Agreements.  The report describes APMA’s experience, structure, and activities relating to APAs and key data on APA activity for 2015.  The IRS separately reports mutual agreement procedure data, which it likely will release within the next few weeks.

Most notably, APA applications for 2015 increased significantly to 183 filed requests, up from about 100 requests in each of the preceding five years.  This increase apparently was driven by the release of Rev. Proc. 2015-41, Procedures for Advance Pricing Agreements (the New Procedure).  Compared to its predecessor (Rev. Proc. 2006-9), the New Procedure provides for higher filing fees and more robust involvement of APMA from the beginning of the APA process, partly by requiring taxpayers to provide more factual information in the APA application.  To avoid the new procedural requirements and increased filing fees, some taxpayers accelerated their APA submissions to file before the New Procedure took full effect on December 30, 2015.

Source & more info: PwC

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