RoyaltyStat Blog

US APMA Program, 2015 APA Statistics

Posted by Ednaldo Silva on Mar 31, 2016 4:12:52 PM

The IRS released its 2015 annual report concerning advance pricing agreements (APA) and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement Program (APA Program). The first report covered calendar years 1991 through 1999. Subsequent reports covered each calendar year 2000 through 2014 separately.

This 17th report describes the experience and activities of the APMA Program during calendar year 2015. It does not provide guidance regarding the application of the arm’s length standard. Part I of this report includes information on the composition and operation of the APMA Program; Part II presents statistical data; and Part III includes general descriptions of various elements of the APAs executed in 2015, including types of transactions covered, transfer pricing methods used, and completion time. RoyaltyStat is listed as a data provider.

Ednaldo Silva (Ph.D.) is founder and managing director at RoyaltyStat. He helped draft the US transfer pricing regulations and developed the comparable profits method called TNNM by the OECD. He can be contacted at:

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Topics: US APMA News & Statistics