The IRS today released an advance version of Announcement 2016-12 providing the annual report on the advance pricing and mutual agreement (APMA) program for 2015 that contains advance pricing agreement (APA) statistics for 2015.
Announcement 2016-12 [PDF 906 KB] reports that:
|Renewals executed in 2015||18||48||0||66|
|Revoked or cancelled||0||0||0||0|
*The total of 183 does not include situations when the taxpayer had paid a user fee but has not yet submitted a substantially complete APA request. As of 31 December 2015, the IRS reports that the APMA program had received 14 user fee filings in addition to the 183 complete APA applications.
Initial impressions of today’s release of the APMA and APA statistics include: (1) that the APMA is resolving more APAs, in particular given an improved negotiating relationship between the United States and Japan; (2) that the increased number of APA filings may be due to the focus on base erosion and profit shifting (BEPS) actions and IRS guidance issued in August 2015 as Rev. Proc. 2015-40 and Rev. Proc. 2015-41; and (3) that the increasing inventory of pending APAs may be an area of some concern.
For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services group in the United States:
Sean Foley | +1 (202) 533-5588 | firstname.lastname@example.org
Steven Wrappe | +1 (408) 367-4185 | email@example.com
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