IRS reissues interim guidance on Advance Pricing Agreement submissions
|Tax Alerts, Transfer Pricing, National/F ...|United States
The interim guidance allows the IRS to determine a taxpayer's suitability for an Advance Pricing Agreement (APA), or, alternatively, another dispute resolution process.
The interim guidance has been reissued because the original guidance expired on April 25, 2025; the updated guidance expires on October 22, 2025.
The new procedures do not seem to have reduced the number of APAs accepted into the APA program and help by requiring earlier determination of taxpayers transfer pricing positions, which …
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