
On March 22, 2024 the IRS’s Advance Pricing Mutual Agreement Program (“APMA” or the “Program”) released Announcement 2024-16 which provides their annual Advance Pricing Agreement (“APA”) report (the “Report”), and the statistics show a record-breaking result for 2023 – 156 APAs resolved. APMA resolves actual and potential transfer pricing disputes and other competent authority matters through United States’ bilateral income tax conventions. This Report focuses on APAs (a solution to prevent future transfer pricing disputes) during calendar year 2023 and provides statistical information about the APA applications received and resolved, including countries involved, types of transactions, and transfer pricing methods. Key takeaways and our observations are noted here.Continue Reading APA Statutory Report Reveals Successful 2023 for APMA