On 14 May, the IRS's Advance Pricing and Mutual Agreement Program (APMA) released a new template that taxpayers must use when requesting an advance pricing agreement (APA) in the US. The new template updates a proposed draft template that the IRS made available for public discussion in September 2017.
An announcement explaining the new template and the IRS response to public comments preceded its release.
Taxpayers that already have prepared an APA request using the 2017 version of the draft template may submit that version but must submit a revised version using this new draft template within 60 days. Taxpayers with pending APA requests should contact their APMA team leaders regarding using the revised template in their cases.
Read more detail in our Insights article from Transfer Pricing