The IRS today released an advance version of Announcement 2018-08 providing the annual report on the advance pricing and mutual agreement (APMA) program for 2017 that contains advance pricing agreement (APA) statistics for 2017.
Announcement 2018-08 [PDF 1.43 MB] reports that:
|Renewals executed in 2017
|Revoked or cancelled
*The total of 101 include the number of complete applications filed per year. As of December 31, 2017, the IRS reports that the APMA program had also received 37 user fee filings that were not yet accompanied by substantially complete APA applications, in addition to the 101 complete APA applications.
Some initial impressions of these APA statistics are:
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 (202) 533-3077 | email@example.com
Mark Martin | +1 (703) 319-3976 | firstname.lastname@example.org
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.