Advance Pricing Arrangement Program

News & Analysis as of

"Notice 2013-79: IRS Proposes Revisions to Advance Pricing Agreement Requests"

On November 22, 2013, the IRS issued Notice 2013-79, which contains draft Revenue Procedures applicable to Advance Pricing Agreements (APAs). The IRS requested comments by March 10, 2014. The Revenue Procedure and the...more

IRS proposes changes to Competent Authority and APA procedures: comments requested by 3/20/2014

The IRS has published for comment two draft revenue procedures that change the existing process for US taxpayers requesting Competent Authority relief under the Mutual Agreement Procedures (MAP) and other provisions of US...more

International Tax News - December 2013

CAYMAN ISLANDS AND US SIGN FATCA AGREEMENT - The United States and the Cayman Islands have signed a so-called Model 1 intergovernmental agreement. The IGA is the first step in bring the Cayman fund industry...more

The Italian Advance Pricing Agreements

The International Ruling Office (the Office) of the Agenzia delle Entrate (the Italian Revenue Agency) has finally released the second issue of the Bulletin, almost three years after the release of the first issue. ...more

Russian Transfer Pricing Law

Recently enacted Russian transfer pricing rules now require companies operating in Russia to file annual documentation in compliance with new regulatory guidance regarding related foreign party and certain domestic party...more

Multilateral Advance Pricing Agreements

As transfer pricing examination and controversy continue to grow, it’s becoming increasingly common for a multinational enterprise group to have advance pricing agreements (APA) with more than two countries (typically...more

CRA Releases New APA Report

This is the eleventh year in which the CRA has issued such a report, which is generally intended to enhance taxpayer awareness of the APA program and to describe (i) current operational status, (ii) relevant changes, and...more

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