The US IRS on Tuesday announced that its Advance Pricing and Mutual Agreement (APMA) program is undergoing a reorganization intended, in part, to allow economists to be more heavily involved in cases.
APMA handles cross-border tax disputes concerning the US, multinational taxpayers, and other countries brought by taxpayers through a tax treaty’s mutual agreement procedure (MAP). APMA also handles multinational firm requests for advance pricing agreements (APAs), which are agreements between the IRS, multinationals, and sometimes a third country designed to settle ahead of time a multinational’s transfer pricing arrangements.
“The move will consolidate APMA’s resources in ways that are designed to improve internal processes, resolve disputes, and increase taxpayer service,” the IRS said, announcing the reorganization.
According to the IRS, APMA will be organized into three groups, groups A, B, and C, each led by an assistant director. Country inventories will generally be aligned at the group level.
Each group will be further divided into two teams, teams 1 and 2. Each of the six teams will be headed by a team manager, responsible for particular APAs or MAP cases. Each team will also be staffed with economists, the Service said.
The Service said that the integration of economists into the teams is a noteworthy feature of APMA’s new organization.
“The program believes this integration will foster collaboration among APMA team members and optimize economist involvement in case analysis, development, and negotiation,” the Service said.
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