The Acting Director of IRS Treaty and Transfer Pricing Operations (TTPO) on April 25 released a memorandum titled “Interim Guidance on Review and Acceptance of Advance Pricing Agreement (APA) Submissions,” which includes an attachment setting forth provisions that will be incorporated into the IRS Internal Revenue Manual by 2025 (collectively, the Guidance).
The Guidance outlines procedures and criteria for TTPO personnel — including Advance Pricing and Mutual Agreement (APMA) personnel — to follow in evaluating whether a proposed APA should be accepted into the APA process or in another TTPO workstream.
