The IRS has issued two revenue procedures on August 12, 2015 with details guidance to request assistance from the US competent authority under income tax treaties and to obtain an advance pricing agreement (APA) program. The proposed version of which was released for public comments in 2013.
Revenue procedure Rev. Proc. 2015-40 provides guidance on the process of requesting and obtaining assistance under US tax treaties from the US Competent Authority. This revenue procedure updates and supersedes Rev. Proc. 2006-54, 2006-2 C.B. 1035. The another revenue procedure Rev. Proc. 2015-41 provides guidance on the process of requesting and obtaining advance pricing agreements from the Advance Pricing and Mutual Agreement program (APMA). This revenue procedure updates and supersedes Rev. Proc. 2006-9, 2006-1 C.B. 278, as modified by Rev. Proc. 2008-31, 2008-1 C.B.1133, which is also superseded.
