Analysis of Proposed Competent Authority, Advance Pricing Agreement Guidelines

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By Jana Lessne and Cameron Taheri, Transfer Pricing Dispute Resolution Services, EVS practice, KPMG LLP | Dec. 19, 2013


From TaxWatch



On November 22, 2013, the IRS released two notices (Notice 2013-78 and Notice 2013-79) containing draft revenue procedures providing guidance and instructions with respect to requesting competent authority (CA) assistance and advance pricing agreements (APAs).

These long-awaited draft revenue procedures represent substantial changes from the current 2006 revenue procedures, and are consistent with the objectives of the Advance Pricing and Mutual Agreement Program (APMA), which is the IRS department that handles CA and APA matters, to enhance integration between CA matters and APAs and to increase transparency and efficiency in these processes.

Overall, these proposed changes are welcome as they should improve the efficient allocation of resources on the part of taxpayers and APMA alike and should provide enhanced clarity to taxpayers about CA and APA processes.

 

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