The IRS today released an advance version of Announcement 2017-03 providing the annual report on the advance pricing and mutual agreement (APMA) program for 2016 that contains advance pricing agreement (APA) statistics for 2016.
Announcement 2017-03 [PDF 564 KB] reports that:
|Renewals executed in 2016||17||32||0||49|
|Revoked or cancelled||0||0||0||0|
*The total of 98 include the number of complete applications filed per year. As of December 31, 2016, the IRS reports that the APMA program had also received 17 user fee filings that were not yet accompanied by substantially complete APA applications, in addition to the 98 complete APA applications.
Initial impressions of APMA and APA statistics include: (1) APA resolutions are down somewhat while APMA focuses on the APA process, (2) APA filings have returned to historic levels after last year’s exceptionally high filings fueled by a new APA Revenue Procedure and based erosion and profit shifting (BEPS) concerns, (3) an unexplained increase in APAs withdrawn, and (4) Japan continues to dominate bilateral APAs executed, filed and inventory, with India filings slightly exceeding Japan filings for the first time.
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
© 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
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.