US Pricing Agreements Down, India’s Up: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and it’s that time of year again: APA data! APMA’s annual report came out, showing the number of executed APAs are down at the office after departures last year. India, meanwhile, reported another record year of APAs signed. In the courts, the IRS appealed its Perrigo loss. And GE wins again in Italy.

The IRS’s Advance Pricing and Mutual Agreement Program’s annual report is chock full of statistical goodies on how the agency did with APAs last year.

The high-level figures were, unsurprisingly, not great.

APMA inked just ...