Common Contracts
1 similar Advance Pricing Agreement contracts
Notice 98-10 PURPOSEAdvance Pricing Agreement • December 19th, 2023
The Internal Revenue Service ("Service") instituted the Advance Pricing Agreement (AAPA@) Program to assist all taxpayers in their efforts to comply with I.R.C. §482. Under an APA, the Service and a taxpayer agree on a transfer pricing methodology (ATPM@) to be prospectively applied to an apportionment or allocation of income, deductions, credits, or allowances between or among two or more organizations, trades, or businesses owned or controlled, directly or indirectly, by the same interests.
