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Navigating the Application Procedure for Advance Pricing Agreements in the US

The US has been a leader in transfer pricing enforcement for several decades, and one of the tools it uses is the advance pricing agreement (APA) program. This program is managed by the Advance Pricing and Mutual Agreement (APMA) program within the Large Business and International Division of the IRS. The legal basis for the […]

US Transfer Pricing-Statutory Rules/Regulations/Circulas

Relevant Rules, Regulations and Statutory Basis: Transfer pricing regulations are covered by the Treasury Regulations (abbreviated “Treas. Reg.”) § 1.482 (referred to as “The Regulations” or “Section 482”) and Treas. Reg. § 1.6662-6 (“Section 6662”) in the United States (“US”). While the first sentence of Section 482 of the current Internal Revenue Code (“the Code” […]

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