IRS: 2015 APA and APMA Program Report Now AvailablePar Robert Robillard - 14 avril 2016
This blogpost originally appeared on rbrt.ca.
The Announcement and Report Concerning Advance Pricing Agreements was released on March 31st, 2016:
« Part I of this report includes information on the structure, composition, and operation of the APMA Program; Part II presents statistical data; and Part III includes general descriptions of various elements of the APAs executed in 2015, including types of transactions covered, transfer pricing methods used, and completion time. »
We learn that, once again, the bulk (70%) of bilateral APAs occurred with Japan (45%) and Canada (25%).
The CPM/TNMM accounted for over 80 % of the APA concluded in 2015.
The complete document is available here.
The 2015 APMA statutory Report has been added to the Transfer Pricing in the USA available here.
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