Part IV. Items of General Interest

Announcement 2015–11

ANNOUNCEMENT AND REPORT

CONCERNING ADVANCE PRICING AGREEMENTS

March 27, 2015

This Announcement is issued pursuant to § 521(b) of Pub. L. 106–170, the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement (APMA) Program, formerly known as the Advance Pricing Agreement (APA) Program. The first report covered calendar years 1991 through 1999. Subsequent reports covered separately each calendar year 2000 through 2013. This sixteenth report describes the experience, structure, and activities of the APMA Program during calendar year 2014. It does not provide guidance regarding the application of the arm’s length standard.

Part I of this report includes information on the structure, composition, and operation of the APMA Program; Part II presents statistical data for 2014; and Part III includes general descriptions of various elements of the APAs executed in 2014, including types of transactions covered, transfer pricing methods used, and completion time.

Hareesh Dhawale Director, Advance Pricing and Mutual Agreement Program

Bulletin No. 2015–15 883 April 13, 2015