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 | email@example.com
Steven Wrappe | +1 (408) 367-4185 | 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.