On 30 March 2018 with an announcement, IRS published Advance Pricing Agreement (APA) report for the calendar year 2017. The report describes the experience, structure, and activities of the APMA Program during calendar year 2017. It does not provide guidance regarding the application of the arm’s length standard.
The report includes information on the structure, composition, and operation of the APMA Program. The report also presents statistical data and general descriptions of various elements of the APAs executed in 2017, including types of transactions covered; transfer pricing methods used, and completion time.
The Report shows that interest in APAs remains strong, with taxpayers filing 101 APA requests in 2017 compared to 98 in 2016. The total number of APAs concluded increased from 86 to 116 and the median amount of time to finalize an APA slightly increased from 32.8 months to 33.8 months.
