EY Global Tax Controversy Flash Newsletter (Issue 59) | US IRS implements pre-screening process for taxpayers seeking APAs
The United States IRS has introduced rigorous pre-screening into the early stages of the Advance Pricing Agreement (APA) process. The interim guidance, which is effective immediately, outlines a procedure under which the Advance Pricing Mutual Agreement team, along with other Transfer Pricing Operations personnel, will review a taxpayer’s prefiling memorandum and recommend whether to proceed…
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