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On March 30, 2018, the IRS Advance Pricing and Mutual Agreement Program (APMA) issued its 19th Annual Statutory Report (the Report) concerning Advance Pricing Agreements (APAs).   The Report states that APA applications for 2017 increased to 101 filed requests, up from 98 in 2016.  These numbers indicate that APAs continue to be an attractive option for companies seeking to manage their tax risks and achieve certainty around their intercompany pricing issues.
Corporate tax personnel and their advisors should evaluate the benefits and opportunities afforded by an APA as a means of proactively resolving potential tax controversies, especially in light of the expected scrutiny of transfer pricing in a post-BEPS world