In early 2012, the Advance Pricing Agreement (APA) Program merged with that portion of the Office of the U.S. Competent Authority (USCA) that resolves transfer pricing cases under the mutual agreement procedures of the United States’ bilateral income tax conventions to form the Advance Pricing and Mutual Agreement (APMA) Program. In late 2020, the Treaty Assistance and Interpretation Team (TAIT) joined APMA. TAIT endeavors to resolve competent authority issues arising under all other articles of U.S. tax treaties including issues arising under U.S. tax treaties relating to estate and gift taxes. APMA’s mission is to resolve actual or potential transfer pricing disputes and other competent authority matters in a timely, principled, and cooperative manner. Announcements Renewal of the qualified maquiladora approach agreement Competent authority filing modifications and APMA APA consultations Update to APA user fees Change to number of required copies for APA and MAP requests Tax treaty information & published guidance U.S. tax treaties U.S. competent authority arrangements Revenue Procedure 2015-41 Revenue Procedure 2015-40 Revenue Procedure 2006-54 Revenue Procedure 2006-9 Revenue Procedure 99-32 PDF Additional APMA Program information APA pre-filing conferences and consultations PDF Annual APA statutory reports Annual competent authority statistics OECD MAP forum United States dispute resolution profile PDF Overview of MAP process Contact us
