IRS Releases Instructions to Staff on Handling APA Requests (2)

The Internal Revenue Service on Monday released instructions for its staff on handling requests for advance pricing agreements.

IRS officials have been publicly discussing such a plan for the last year. The guidance describes a more selective approach to granting requests for APAs, agreements that are highly desirable to companies because they provide certainty over their transfer pricing.

“The guidance certainly creates some big changes to the APA world as we now know it,” said Sharon Katz-Pearlman, a shareholder at Greenberg Traurig in New York.

“Today, taxpayers and their representatives are accustomed to submitting APAs, and for the most part, ...