The Internal Revenue Service has issued a new template that corporate taxpayers need to use when asking for an advance pricing agreement with the IRS.
Advance pricing agreements are prior agreements between multinational companies and the IRS on the appropriate transfer pricing method to use for a given set of transactions with a specific time period.
The IRS released a proposed version of the template for comment last September, along with a filled-in and annotated example of how the template could be edited by a business taxpayer to produce an initial draft of the agreement. It released the new template last week.
The IRS’s Advance Pricing and Mutual Agreement Program received some constructive comments on the proposed template and plans to make periodic revisions as it gets more experience in how the template is being used. The IRS is still looking for feedback on the template it released. For more information, visit https://www.irs.gov/businesses/corporations/apma.