The US IRS on May 11 released a new template for taxpayers to use when requesting an advance pricing agreement (APA), which is an agreement between a multinational taxpayer and one or more tax authorities establishing the multinationals’ transfer pricing.
The final version of the template continues to use an options-based format and follows a draft version released for public comment in September 2017 with some changes.
The IRS said one issue remains outstanding that requires further study and has asked for further taxpayer input.
The IRS would like to know if additional guidance is needed on whether a covered method should be re-applied to take into account certain adjustments between an APA-covered entity and a non-APA-covered entity, and any resulting competent authority resolution, that would affect the testing of financial results under the covered method.
Comments are invited on the frequency with which this question might arise, the Service said.
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