Our International Tax Group unpacks recent IRS guidance and public comments that reveal how the agency is changing its advance pricing agreement (APA) procedures. The Large Business and International Division released a...more
On March 27, 2023, the Internal Revenue Service (IRS) issued its Announcement and Report Concerning Advance Pricing Agreements (APA Report) for 2022, which presents the key APA results of the IRS’s Advance Pricing and Mutual...more
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
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
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