May 16, 2023|11:00 AM - 12:30 PM ET
Webinar
The Tax Practices of Holland & Knight and Simmons & Simmons invite you to a joint webinar focusing on the recent IRS Interim Guidance on the Review and Acceptance of Advance Pricing Agreement (APA) Submissions.
The guidance, issued on April 25, 2023, requires IRS personnel who review APA requests to apply new selectivity criteria to determine whether an APA request should be accepted or, if not, whether an alternative transfer pricing workstream, such as the International Compliance Assurance Program (ICAP) or a joint audit, should be proposed to best resolve a transfer pricing issue for taxpayers and the IRS. The Interim Guidance reflects a marked change in past practices dealing with the acceptance of APA requests.
Topics covered:
- How transfer pricing issues are resolved
- Current APA request practices
- The Interim Guidance – reasons for issuance, what it provides and how it works
- How a taxpayer should proceed under the Interim Guidance if it would like to pursue a unilateral, bilateral or multilateral request for an APA, or a renewal
- How transfer pricing practitioners in Europe view the Interim Guidance
- How the Interim Guidance selectivity criteria interrelates with criteria in Europe