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US IRS official says enhanced IRS pre-filing process will provide taxpayers with a more robust view of APA suitability

24 March 2023

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Tax Alerts, Transfer Pricing, Legislation & Policy

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United States

The  In an online panel discussion on 7 March 2023, a US Internal Revenue Service (IRS) official stated that the IRS intends to implement an enhanced APA pre-filing process that will allow taxpayers to obtain the Advance Pricing and Mutual Agreement (APMA) Program's preliminary views about the most efficient process for managing a taxpayer's transfer pricing uncertainty, including the suitability of requesting an Advance Pricing Agreement (APA).The official also indicated that the IRS intends to be more selective regarding the APA requests admitted into the program without targeting a reduction in inventory.As a result, taxpayers currently considering an APA may...