IRS Plans to Apply New APA Guidance Holistically, Official Says

The IRS expects to take a “holistic approach” in applying its new guidance for advance pricing agreement requests, Holly Paz, acting commissioner of the IRS’s Large Business and International Division, said Thursday.

“It’s not a one-size-fits-all,” Paz said at the 2023 NYU Tax Controversy Forum.

• The IRS in May sent a memo to employees providing interim guidance on accepting requests for advance pricing agreements, in which taxpayers work with the IRS to give them certainty over their transfer pricing arrangements. The memo outlines the more selective criteria the agency is applying to decide which requests are accepted.
• The guidance isn’t ...