IRS expands US APA programme
May 29, 2008
Tax authority issues advance notice of key changes
The Internal Revenue Service’s (IRS) advance pricing agreement programme will be expanded. The IRS has issued a notice giving taxpayers and advisers early notice of the changes which take effect on June 9. It now covers attribution of profits to a permanent establishment and determination of effectively connected income. These have been available to US taxpayers through advance rulings under the Prefile Agreement (PFA) programme. But this is the first time that they have been available to users of advance pricing agreements (APAs).
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