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Tax news and developments

In brief

On 26 March 2024, the IRS Advance Pricing and Mutual Agreement (APMA) Program issued their 25th annual Advance Pricing Agreement (APA) report describing the experience, structure, and activities of the APMA Program during calendar year 2023. The report provides statistical information about the numbers of APA applications received and resolved during the year, including countries involved and transfer pricing methods (TPMs) employed. This article identifies key takeaways based on the data from the report and our experience advising companies during the APA process.

Click here to read the full alert.


Amanda Worcester Martin is a partner within the Firm’s Global Tax Practice. She routinely advises companies on a variety of corporate and international tax matters, particularly in the areas of transfer pricing, tax controversy involving international tax issues, and corporate M&A matters.


Wenham Shen is a Director of Economics in Baker McKenzie, Washington, DC office.

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