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 with the APA. As part of this screening, the prefiling review team may recommend shifting the taxpa…
EYEY Global Tax Controversy Flash Newsletter (Issue 59) | US IRS implements pre-screening process for taxpayers seeking APAs
