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 employed. This article identifies key takeaways based on the data from the report and our experience advising companies during the APA process.

On 29 January 2024, the OECD issued the first statistics on the International Compliance Assurance Programme (ICAP). These statistics cover all 20 ICAP cases completed since the beginning of the program in 2018 through October 2023.

Companies want and need to take action to deal with the uncertainty caused by COVID-19, or to take measures to enable their operations to weather possible outbreaks or similar events in the future. Those actions have transfer pricing implications, and if companies have an Advance Pricing Arrangement (APA), or are…