IRS: 2015 APA and APMA Program Report Now Available
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 DRTP’s page on Transfer Pricing in the USA available here.
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