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Details

  • Service: Tax, Global Transfer Pricing Services
  • Type: Regulatory update
  • Date: 5/29/2014

United States - Competent Authority statistics for 2013 

May 29:  The IRS released a report providing statistics of Competent Authority actions for 2013.*

*2013 statistics are for 15 months: 1 October 2012 - 31 December 2013

Background

In the United States, the Competent Authority has jurisdiction over both the Advance Pricing and Mutual Agreement (APMA) Program and the Treaty Assistance and Interpretation Team (TAIT).


  • APMA has primary responsibility for cases arising under the business profits and associated enterprises articles of U.S. income tax treaties.
  • TAIT has primary responsibility for cases arising under all other articles of U.S. income tax treaties, including, but not limited to, articles concerning residence, dividends, interest, royalties, income from employment, social security, annuities, pensions and pension funds, other income, and limitation on benefits. TAIT also handles cases arising under U.S. estate and gift tax treaties.

2013 statistics

The IRS report [PDF 41 KB] provides statistics on cases handled by both APMA and TAIT. Concerning the APMA statistical information under the mutual agreement procedure (MAP) program for 2013, the information is briefly summarized as follows:


  • 266 requests received in 2013 (up from 181 requests received in 2012)
  • 159 cases resolved in 2013 (up from 90 cases resolved in 2012)
  • 524 pending cases (up from 403 requests pending at the end of 2012)


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