Advance Pricing Agreement Program
The Advance Pricing Agreement (APA) Program is designed to resolve actual or potential transfer pricing disputes in a principled, cooperative manner, as an alternative to the traditional adversarial process. An APA is a binding contract between the IRS and a taxpayer by which the IRS agrees not to seek a transfer pricing adjustment for a covered transaction if the taxpayer files its tax return for a covered year consistent with the agreed transfer pricing method.
- APA Program Documentation
- Published Guidance & Tax Treaty Information
- APA and Mutual Agreement Program Realignment
- New Procedures for APA and LOB User Fees
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