U.S. to Exchange Unilateral APAs as per BEPS Action 5 by the End of the Year
According to recent comments from IRS officials, the IRS will begin the exchange of information on unilateral advance pricing agreements (APAs) by the end of the year as per BEPS Action 5. Although Action 5 sets out six categories of rulings to be exchanged, the IRS has so far only identified unilateral APAs as meeting the conditions for exchange. The six categories under Action 5 include:
- Rul…