In early 2012, the Advance Pricing Agreement (APA) Program merged with that portion of the Office of the U.S. Competent Authority (USCA) that resolves transfer pricing cases under the mutual agreement procedures of the United States’ bilateral income tax conventions to form the Advance Pricing and Mutual Agreement (APMA) Program. In late 2020, the Treaty Assistance and Interpretation Team (TAIT) joined APMA. TAIT endeavors to resolve competent authority issues arising under all other articles of U.S. tax treaties including issues arising under U.S. tax treaties relating to estate and gift taxes. APMA’s mission is to resolve actual or potential transfer pricing disputes and other competent authority matters in a timely, principled, and cooperative manner. Announcements Renewal of Competent Authority Agreement on Maquiladoras Competent Authority Filing Modifications and APMA APA Consultations Change to APA User Fees Change to Number of Required Copies for APA and MAP Requests Tax Treaty Information & Published Guidance U.S. Tax Treaties U.S. Competent Authority Arrangements Revenue Procedure 2015-40 PDF Revenue Procedure 2015-41 PDF Present Law and Background Related to Possible Income Shifting and Transfer Pricing (JCX-37-10), July 20, 2010 Revenue Procedure 2006-54 Revenue Procedure 2006-9 Revenue Procedure 99-32 PDF Additional APMA Program information APA Template under Revenue Procedure 2015-41 APA Pre-Filing Conferences and Consultations PDF APA User Fee Procedures Annual Report Summary Form PDF Annual APA Statutory Reports Annual Competent Authority Statistics OECD MAP Forum United States Dispute Resolution Profile PDF Overview of MAP Process Contact us
