Rev. Procs. 2015-40, 2015-41: Guidance for competent authority assistance, APAs

Guidance for competent authority assistance, APAs

The IRS today released two revenue procedures that offer guidance on the process for taxpayers to request and obtain the assistance of the U.S. Competent Authority under the U.S. network of income tax treaties and that provide guidance regarding the advance pricing agreement (APA) program.

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  • Rev. Proc. 2015-40 [PDF 245 KB] provides guidance on the process of requesting and obtaining assistance under U.S. tax treaties from the U.S. Competent Authority, acting through the Advance Pricing and Mutual Agreement Program and the Treaty Assistance and Interpretation Team of the Deputy Commissioner (International) Large Business and International Division of the Internal Revenue Service.
  • Rev. Proc. 2015-41 [PDF 241 KB], released along with Rev. Proc. 2015-40, provides guidance with respect to advance pricing agreements (APAs).

 

Read initial reports of these revenue procedures in TaxNewsFlash-Transfer Pricing

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