Bloomberg Tax Quotes Elizabeth Stevens on New IRS Instructions For Advance Pricing Agreements

The Internal Revenue Service on Monday released instructions for its staff on handling requests for advance pricing agreements.

IRS officials have been publicly discussing such a plan for the last year. The guidance describes a more selective approach to granting requests for APAs, agreements that are highly desirable to companies because they provide certainty over their transfer pricing.

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“APMA has said publicly that it has no intent to reduce the number of APAs accepted into the program,” said Elizabeth Stevens, a Member at Caplin & Drysdale. “Maybe that’s so, and they’re simply spelling out transparently the analytical framework that they’ve been applying. But this sure reads like a menu of ways to say ‘no’ to a taxpayer’s APA request.”

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