The US IRS today released statistics on the performance of its advance pricing agreement (APA) program in 2017, revealing that the tax agency signed 116 APAs that year.
APA are agreements signed between the tax agency and multinational taxpayer resolving transfer pricing issues.
The number of APAs signed in 2017 was an improvement over the previous year, where only 86 APAs were signed. The agency signed 110 APAs in 2015, 101 in 2014, 145 in 2013, and 140 in 2012.
The IRS said that 40 percent of the agreements executed were new agreements rather than renewals, as was the case last year.
Of the APAs signed in 2017, 30 were unilateral, 85 were bilateral, and 9 were multilateral. Last year. those numbers were 21 unilateral, 65 bilateral, and zero multilateral.
Over half the bilateral APAs were signed with Japan while agreements with Canada comprised 16 percent of the total. Agreements were also reached involving Korea, Switzerland, Germany, and other countries.
The median time required to complete an APA in 2017 increased slightly over the previous year to 33.8 months, as compared to 32.8 months in 2016. It took 31.9 months to complete and APA in 2015 and 35.3 months in 2014.
According to the IRS data, applications for new APAs in 2017 totaled 101, similar to in recent years, except for 2015, which saw a surge in applications. In 2011–2016, applications numbered 96, 126, 111, 108, 183, and 98, respectively.
The Service said it also received 37 filings that were not complete.
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