Transfer Pricing Times: IRS Advance Pricing And Mutual Agreement Program Releases Annual Report

In this issue: The Advance Pricing and Mutual Agreement program released its annual report and announced the introduction of a new Excel-based model which taxpayers that are seeking an Advance Pricing Agreement may be required to complete as part of the APA process; the IRS and U.S. Treasury issued proposed regulations under section 250 of the U.S. Internal Revenue Code; Canada's federal government tabled a budget that included two new measures specific to transfer pricing, reaffirmed Canada's commitment to the OECD/G20 BEPS initiative and included a fourth consecutive wave of additional funding for tax enforcement; India's Ministry of Finance issued a press release announcing the finalization of a bilateral agreement for exchange of Country-by-Country Reports between India and the United States; the Australian Taxation Office issued Practical Compliance Guideline PCG 2019/1 which addresses its transfer pricing compliance approach to inbound distributors; the Vietnam