The IRS is “taking a careful look” at the advance pricing agreements it signs off on and may be more selective about which cases are accepted in the future, an official said.
Many tax authorities sign advance pricing agreements, or APAs, with companies to give both sides certainty about how much tax the company will pay and what its transfer pricing arrangements will look like over a number of years. Transfer pricing is the determination of how a company sets its intragroup prices.
- The IRS’s procedures around APAs may see some changes in the future, said Jennifer Best, director of ...