US could change practice on unilateral APA requests
February 02, 2011
Matthew Gilleard - ITR
The APA Program in the US could restrict requests for unilateral advance pricing agreements, where the counterparty affiliate is located in a country that has a tax treaty with the US.
Sources say that officials have indicated that the change may mean that the Program will generally require taxpayers to seek bilateral APAs in these situations in the future, and will only accept unilateral agreements in limited circumstances. Outgoing APA director Craig Sharon recently held a public discussion regarding this issue because it is something many practitioners have experienced lately.
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