ContractAdvance Pricing Agreement • June 26th, 2014
Contract Type FiledJune 26th, 2014In the first quarter of calendar year 2012, the Advance Pricing Agreement (“APA”) Program merged with the division of the Office of the U.S. Competent Authority (“USCA”) that resolves transfer pricing cases under the mutual agreement procedures of United States bilateral income tax conventions to form the new Advance Pricing and Mutual Agreement Program (“APMA”). Before the formation of APMA, bilateral APA cases involved both the APA Program and USCA and cases were tracked separately by each office. The separate tracking of cases was eliminated with the formation of APMA, and the tables that tracked APA case data have been eliminated. APA information is reported separately in the APA statutory report.