Bulletin No. 2026–16

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Bulletin No. 2026–16

April 13, 2026

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

ADMINISTRATIVE

INCOME TAX

Announcement 2026-8, page 813.

Rev. Rul. 2026-8, page 812.

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

Program (APMA Program), formerly known as the Advance

Pricing Agreement Program (APA Program). This twenty-seventh report describes the experience, structure, and activities

of the APMA Program during calendar year 2025.

Finding Lists begin on page ii.

Fringe benefits aircraft valuation formula. For purposes of

section 1.61-21(g) of the Income Tax Regulations, relating to

the rule for valuing non-commercial flights on employer-provided aircraft, the Standard Industry Fare Level (SIFL) centsper-mile rates and terminal charge in effect for the first half

of 2026 are set forth.

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and

enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument

of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application

of the tax laws, including all rulings that supersede, revoke,

modify, or amend any of those previously published in the

Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of

internal practices and procedures that affect the rights and

duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

on the application of the law to the pivotal facts stated in

the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature are

deleted to prevent unwarranted invasions of privacy and to

comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the

force and effect of Treasury Department Regulations, but they

may be used as precedents. Unpublished rulings will not be

relied on, used, or cited as precedents by Service personnel in

the disposition of other cases. In applying published rulings and

procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered,

and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless

the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

by the Department of the Treasury’s Office of the Assistant

Secretary (Enforcement).

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

April 13, 2026 

Bulletin No. 2026–16

Part I

Section 61. Gross Income

Defined

26 CFR 1.61-21: Taxation of Fringe Benefits

Rev. Rul. 2026-8

For purposes of the taxation of fringe

benefits under section 61 of the Internal

for the period during which the flight was

taken by the appropriate aircraft multiple

provided in section 1.61-21(g)(7) and then

adding the applicable terminal charge. The

SIFL cents-per-mile rates in the formula

and the terminal charge are calculated by

the Department of Transportation (DOT)

and are reviewed semi-annually.

The following chart sets forth the terminal charge and SIFL mileage rates:

Period During Which

Terminal

the Flight Is Taken

Charge

1/1/26 - 6/30/26

$54.48

SIFL Mileage

Rates

Up to 500 miles

= $.2980 per mile

501-1500 miles

= $.2272 per mile

Over 1500 miles

= $.2184 per mile

DRAFTING INFORMATION

The principal author of this revenue ruling is Kathleen Edmondson of the Office

April 13, 2026

Revenue Code, section 1.61-21(g) of the

Income Tax Regulations provides a rule

for valuing noncommercial flights on

employer-provided aircraft. Section 1.6121(g)(5) provides an aircraft valuation

formula to determine the value of such

flights. The value of a flight is determined

under the base aircraft valuation formula

(also known as the Standard Industry Fare

Level formula or SIFL) by multiplying

the SIFL cents-per-mile rates applicable

of Associate Chief Counsel (Employee

Benefits, Exempt Organizations and

Employment Taxes). For further information regarding this revenue ruling, contact

812

Ms. Edmondson at (202) 317-6798 (not a

toll-free call).

Bulletin No. 2026–16

Part III

Announcement and Report Concerning Advance Pricing Agreements

Announcement 2026-8

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 Program (APMA Program), formerly known as the Advance Pricing Agreement

Program (APA Program). The first report covered calendar years 1991 through 1999. Subsequent reports covered each calendar year

2000 through 2024 separately. This twenty-seventh report describes the experience, structure, and activities of the APMA Program

during calendar year 2025. 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; and Part III includes general descriptions of various elements of the APAs executed in 2025, including types of transactions

covered, transfer pricing methods used, and completion time.





Bulletin No. 2026–16

John M. Wall

Director, APMA Program

813

April 13, 2026

Part I. The APMA Program – Structure, Composition, and Operation

[Pub. L. 106-170 § 521(b)(2)(A)]

The Advance Pricing and Mutual Agreement Program (APMA) is part of the U.S. Competent Authority’s Office under Treaty &

Transfer Pricing Operations (TTPO) within the Large Business and International Division of the IRS.

As of December 31, 2025, APMA’s APA cases were handled by a staff of 108, comprising 63 team leaders, 30 economists, 12 managers, and 3 assistant directors.1 Each assistant director oversees four managers who lead teams consisting of both team leaders and

economists. APMA’s main office is in Washington, DC, and it also has offices in northern California, southern California, Florida, and

the Boston, Chicago, Denver, New York City, and Seattle metropolitan areas. A list of primary APMA contacts is available at https://

www.irs.gov/businesses/corporations/apma-contacts.

On August 31, 2015, the current revenue procedure governing APA applications was published in 2015-35 I.R.B. on page 263. Revenue Procedure (Rev. Proc.) 2015-41 provides guidance, information and instructions on APA requests and the administration of

APAs. Rev. Proc. 2015-41 updates and supersedes Rev. Proc. 2006-9, 2006-1 C.B. 278, as modified by Rev. Proc. 2008-31, 2008-1

C.B. 1133, which is also superseded.

The model for APAs covered by Rev. Proc. 2006-9 was updated to serve as the current model APA for APAs covered by Rev. Proc.

2015-41 (instead of the model APA that had been issued with Rev. Proc. 2015-41). The model APA that is included as Appendix 1 to

this report remains unchanged since last year’s report.

In late 2020, TTPO’s Treaty Assistance and Interpretation Team (TAIT) joined APMA, bringing the total number of groups in APMA to four. The three legacy APMA groups have primary

responsibility for cases arising under the business profits and associated enterprises articles of U.S. tax treaties. TAIT endeavors to resolve competent authority issues arising under all other

articles of U.S. tax treaties including issues arising under U.S. tax treaties relating to estate and gift taxes. As such, TAIT is separate from APMA’s APA program, and the total numbers of

team leaders and managers handling APA cases do not include TAIT analysts and managers.

1

April 13, 2026

814

Bulletin No. 2026–16

Part II. APMA Program Statistical Data

[Pub. L. 106-170 § 521(b)(2)(C)(i-viii)]

Table 1: APA Applications Filed

§ 521(b)(2)(C)(i)

Part II. APMA Program Statistical Data

[Pub. L. 106-170 § 521(b)(2)(C)(i-viii)]

Table 1: APA Applications Filed Unilateral

§ 521(b)(2)(C)(i)

Filed 1991-19992

Unilateral

Filed 2000-2024

713

2

Filed 1991-1999

Filed in 2025

23

Filed 2000-2024

713

Total Filed 1991-2025

Filed in 2025

23

Total Filed 1991-2025

Bilateral

Bilateral

2,285

153

Multilateral

Multilateral

56

2

2,285

153

56

2

Total

401

Total

3,054

401

178

3,054

3,633

178

3,633

Applications Filed

2016-2025

250

200

150

100

50

0

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

All Other Countries

10%

Switzerland

3%

Bilateral APAs

Filed by Country 2025

India

26%

Denmark

2%

United Kingdom

4%

Mexico

4%

Germany

5%

Korea

7%

Japan

24%

Canada

7%

Italy

8%

The charts above illustrate the number of complete applications filed per year and the percentage

The charts above illustrate the number of complete applications filed per year and the percentage of bilateral requests received in

requests

received

in31,

2025

per

foreign

As31

ofuser

December

APMA

had

2025 of

perbilateral

foreign country.

As of

December

2025,

APMA

had country.

also received

fee filings31,

that2025,

were not

yet accompanied

by a

also received

user

fee filings

that were

not

yet

accompanied

by a substantially complete APA

substantially

complete31

APA

application,

in addition

to the

178

complete

APA applications.

application, in addition to the 178 complete APA applications.

The first APA Statutory Report, which compiled APA data from 1991-1999, did not report the cumulative number

of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.

2

The first APA Statutory Report, which compiled APA data from 1991-1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals

cannot be reported in that manner.

2

3

Bulletin No. 2026–16

815

April 13, 2026

Table 2: Executed3 and Pending APAs

§ 521(b)(2)(C)(ii-vi)

3

Table 2: Executed and Pending APAs

§ 521(b)(2)(C)(ii-vi)

Unilateral

Unilateral

Total Executed 1991-2024

734

Total Executed 1991-2024

734

Total Executed in 2025

14

Total Executed in 2025

14

Total Executed 1991-2025

748

Total Executed 1991-2025

748

Total Pending as of 12/31/2025

61

Renewals Executed in 2025

Renewals Executed in 2025

Renewals Pending4 as of 12/31/2025

4

13

Total Pending as of 12/31/2025

Renewals Pending as of 12/31/2025

Bilateral

Bilateral

1,798

Multilateral

543

18

61

13

49

49

Multilateral

34

1,798

34

90

6

90

6

1,888

40

1,888

40

543

39

39

256

256

Total

Total 2,566

2,566

110

110

2,676

2,676

622

18

622

3

55

310310

3

5

5

55

APAs Executed

2016-2025

200

150

100

50

0

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Bilateral APAs

Executed

by Country 2025

All Other Countries

10%

United Kingdom

3%

Switzerland

3%

Ireland

3%

Korea

5%

Germany

5%

India

35%

Japan

25%

Canada

11%

In 2025, the percentage of APA renewals executed decreased (50 percent of all APAs executed

in 2025

versus 58

percent

of all

APAsdecreased

executed(50inpercent

2024).ofThe

charts

aboveinillustrate

trends

in theof all APAs

In 2025,

the percentage

of APA

renewals

executed

all APAs

executed

2025 versus

58 percent

number

of

APAs

executed

per

year

and

the

countries

involved

in

the

bilateral

APAs

that

were

executed in 2024). The charts above illustrate trends in the number of APAs executed per year and the countries involved in the bilateral APAs

that were

executed in 2025.

executed

in 2025.

3

4

3

4

“Executed APAs” refers to APAs that were finalized and includes both initial and renewal APAs.

The number of renewals still pending as of year-end is also included in the total number of pending APAs.

“Executed APAs” refers to APAs that were finalized and includes both initial and renewal APAs.

The number of renewals still pending as of year-end is also included in the total number of pending APAs.

April 13, 2026

4

816

Bulletin No. 2026–16

Pending APAs

2016-2025

800

600

400

200

0

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

All Other Countries

16%

United Kingdom

4%

Germany

4%

Italy

5%

Korea

6% Mexico

6%

Pending Bilateral APAs

by Country

Japan

27%

India

21%

Canada

11%

As the top chart illustrates, the number of pending requests increased compared to December 31,

As the2024.

top chart

illustrates,

the number

of pending

requests

increased

to December

31, 2024.

of December 31, 2025,

As of

December

31, 2025,

slightly

less than

half compared

of the pending

bilateral

APAAsrequests

slightly less than half of the pending bilateral APA requests involved either Japan or India.

involved either Japan or India.

Table 3: APAs Revoked or Cancelled and Applications Withdrawn

Table 3: APAs Revoked or Cancelled and Applications Withdrawn

§ 521(b)(2)(C)(vii)

§ 521(b)(2)(C)(vii)

5

5

Revoked

or Cancelled

Revoked

or Cancelled

1991-20001991-2000

Revoked

or Cancelled

Revoked

or Cancelled

2001-20242001-2024

Revoked

or

Cancelled

Revoked or Cancelled in 2025 in 2025

Revoked

or Cancelled

Total Total

Revoked

or Cancelled

1991-2025 1991-2025

Unilateral

Unilateral

8

0

Withdrawn 1991-20006

Withdrawn 1991-20006

Withdrawn 2001-2024

Withdrawn 2001-2024

Withdrawn in 2025

Withdrawn in 2025

Withdrawn

1991-2025

Withdrawn

1991-2025

80

1

8

0

80

1

Bilateral

Bilateral

2

0

2

0

183

9

183

9

Multilateral

Multilateral

0

0

2

0

0

0

Total

Total

11

10

10

00

11

11

2

0

49

265

265

10

10

49

324

324

The first APA Statutory Report, which compiled APA data from 1991-1999, and the second APA Statutory

Report, which compiled APA data for 2000, did not report the cumulative number of applications for those years by

submission type, so the cumulative totals cannot be reported in that manner.

6

See supra note 5.

5

5

5

The first APA Statutory Report, which compiled APA data from 1991-1999, and the second APA Statutory Report, which compiled APA data for 2000, did not report the cumulative number

of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.

6

See supra note 5.

Bulletin No. 2026–16

817

April 13, 2026

Table 4: APAs Executed in 2025 by Industry

§ 521(b)(2)(C)(viii)

Table 4: APAs Executed in 2025 by Industry

§ 521(b)(2)(C)(viii)

Industry

Industry

Wholesale/Retail Trade

Wholesale/Retail Trade

32

Services Table 4: APAs Executed in 2025 by Industry

Services

28

§ 521(b)(2)(C)(viii)

Manufacturing

Manufacturing Industry

22

Management

Management

16

Wholesale/Retail

Trade

32

Finance,

InsuranceInsurance

and Real Estate

Finance,

and

Real

Estate

8

Services

28

All Other

Industries

All Other

Industries

4

Manufacturing

22

Management

Finance, Insurance and Real Estate

All Other Industries

Wholesale/Retail

Trade

29%

32

28

22

16

8

4

16

APAs8Executed

in 2025 4by Industry

APAs Executed

in 2025 by Industry

Manufacturing

20%

Manufacturing

Services

20%

25%

Wholesale/Retail

Trade

29%

All Other

Industries

4%

Services

25%

Finance, Insurance

and Real Estate

All Other Industries

7%

4%

Finance, Insurance

and Real Estate

TableTable

4a: Wholesale/Retail

Trade

APAs

Executed

in 2025

4a: Wholesale/Retail Trade 7%

APAs

Executed in 2025

Management

15%

Management

15%

Type of Wholesale/Retail Trade

Table

4a:Wholesalers,

Trade

APAs Executed in 2025 14

Type

ofWholesale/Retail

Wholesale/Retail

Trade

Merchant

Durable

Goods

Type

of

Wholesale/Retail

Trade

Merchant

Wholesalers,

Durable Goods

14

Merchant

Wholesalers,

Nondurable Goods

6

Merchant

Wholesalers,

Durable

Goods

14

Merchant

Wholesalers,

Nondurable

Goods

6

General

Merchandise

Stores

5

Merchant Wholesalers, Nondurable Goods

6

GeneralAll

Merchandise

Stores

5

Other

GeneralWholesalers

Merchandise Stores

57

All Other Wholesalers

7

All Other Wholesalers

7

Type of Wholesale/Retail Trade APAs

Executed in 2025

Type of Wholesale/Retail

Trade APAs

Executed in 2025

All Other

Wholesalers

All Other

Wholesalers

22%

Merchant

Merchant Durable

Wholesalers,

Wholesalers,

Durable

Goods

Goods

44%

22%

44%

Merchant

General

Merchandise

General Merchandise

Stores

Stores

15%15%

Merchant

Wholesalers,

Wholesalers,

Nondurable

Goods

Nondurable Goods

19%

19%

6

April 13, 2026

818

Bulletin No. 2026–16

Part III. General Descriptions of APAs Executed in 2025

[Pub. L. 106-170 § 521(b)(2)(D) and (E)]

Part III. General Descriptions of APAs Executed in 2025

Part

III. General

Descriptions

of APAs Executed

Nature of the Relationships

[Pub.

L. 106-170

§ 521(b)(2)(D)

and (E)]in 2025

[Pub.

L.

106-170

§

521(b)(2)(D)

and

(E)]

§ 521(b)(2)(D)(i)

Nature

of the Relationships

Nature

of the Relationships

§

521(b)(2)(D)(i)

Relationships between Controlled Parties

§ 521(b)(2)(D)(i)

U.S. Parent &

Non-U.S.

Relationships between Controlled

Parties

Subsidiary

U.S. Parent &

45%

Non-U.S.

Subsidiary

45%

Sister Companies

10%

Sister Companies

10%

Non-U.S. Parent &

U.S. Subsidiary

45%

Non-U.S.

Parent &

U.S. Subsidiary

45%years, when more than half of the APAs executed involved

In a change from previous

transactions between non-U.S. parents and U.S. subsidiaries7 (for example, 56 percent in 2024),

In a change

from

previous

when

more

half

of the

APAs

executed

involved

In a change

from

previous

whenyears,

more

than

halfinvolved

of the than

APAs

executed

involved

transactions

between

non-U.S.

parents and U.S.

2025

had as

manyyears,

executed

APAs

that

transactions

between

U.S. parents

and

non-U.S.

7

7APAs that involved transactions between U.S. parents

subsidiaries

(for

example,

56

percent

in

2024),

2025

had

as

many

executed

(for example, 56 percent in 2024),

transactions as

between

non-U.S.non-U.S.

parents and

U.S.and

subsidiaries

subsidiaries

those between

parents

U.S. subsidiaries.

and non-U.S.

subsidiaries

those between

non-U.S.

parents and

U.S. subsidiaries.

2025 had

as manyasexecuted

APAs

that involved

transactions

between U.S. parents and non-U.S.

subsidiaries

as those between

non-U.S.

subsidiaries.

Covered

Transactions,

Functions

andparents

Risks, and

andU.S.

Tested

Parties

Covered Transactions, Functions and Risks, and Tested Parties

§

521(b)(2)(D)(ii-iii)

§ 521(b)(2)(D)(ii-iii)

Covered Transactions, Functions and Risks, and Tested Parties

§ 521(b)(2)(D)(ii-iii)

Types of Covered Transactions

All Other Types of

Transactions

Types of Covered Transactions Provision of Services

by a Non-U.S. Entity

Use of Intangible Property by

2%

a Non-U.S. Entity All Other Types of

Provision30%

of Services

Transactions

7%

by

a

Non-U.S.

Entity

Use of Intangible Property by

2%

30%

a Non-U.S. Entity

Sale of Tangible Property

7%

from the U.S.

8% Property

Provision of Services

Sale of Tangible

by a U.S. Entity

from the U.S.

Use of Intangible

Property

by

a

8%

Provision23%

of Services

U.S. Entity

by a U.S. Entity

10% Property bySale

Use of Intangible

a of Tangible Property into the U.S.

23%

20%

U.S. Entity

Sale of Tangible Property into the U.S.

10%

20%

8

8

in APAs

executed

involve

the provision of services.

of the transactions

Most Most

of the transactions

covered incovered

APAs executed

in 2025

involve in

the2025

provision

of services.

8

in APAs

in 2025functions

involve and

the risks.

provision

of services.

of of

the

transactions

In the Most

majority

APAs,

the coveredcovered

transactions

involveexecuted

numerous business

For instance,

with respect to functions, APAs involving manufactured products typically involve a controlled group that conducts research and development (R&D),

engages in product design and engineering, manufactures the product, markets and distributes the product, and performs support

7

functions

legal, finance, where

and human

resources.

Regarding

controlled

groupsubsidiaries.

may assume a variety of risks, including

Thesuch

termas“subsidiaries,”

used in

this report,

refers torisks,

both the

direct

and indirect

8 risks, R&D risks, financial risks, credit and collection risks, product liability risks, and general business risks. In the APA

market

APAs often cover more than one type of transaction.

7

evaluation

a significantwhere

amount

of time

and

effortrefers

is devoted

understanding

how

functions and risks are allocated among

Theprocess,

term “subsidiaries,”

used

in this

report,

to bothtodirect

and indirect

subsidiaries.

8

7

APAs often

more thanthat

oneare

type

of transaction.

the controlled

groupcover

of companies

party

to the covered transactions.

For methods requiring the selection of a tested party, the

tested party chosen generally will be the least complex of the controlled taxpayers.

7

7

8

The term “subsidiaries,” where used in this report, refers to both direct and indirect subsidiaries.

APAs often cover more than one type of transaction.

Bulletin No. 2026–16

819

April 13, 2026

process, a significant amount of time and effort is devoted to understanding how functions and

risks are allocated among the controlled group of companies that are party to the covered

transactions. For methods requiring the selection of a tested party, the tested party chosen

generally will be the least complex of the controlled taxpayers.

Types of Tested Parties

Non-U.S. Service

Provider

41%

U.S. Distributor

23%

All Other Types of

Tested Parties

2%

U.S. Manufacturer

9%

Non-U.S. Distributor

9%

U.S. Service Provider

16%

In a change from previous years, U.S. distributors, U.S. manufacturers, and U.S. service

9

In a change

fromcombined,

previous years,

U.S. distributors,

U.S.

manufacturers,

andparties

U.S. service

combined,

i.e., providers

48 percent

(down comprised

from 59 less than

providers

comprised

less than

half

of the tested

half of the tested parties9 i.e., 48 percent (down from 59 percent in 2024), with non-U.S. service providers comprising 41 percent (up

percent in 2024), with non-U.S. service providers comprising 41 percent (up from 31 percent in

from 31 percent in 2024).

2024).

Transfer Pricing Methods Used

Transfer Pricing Methods Used

§ 521(b)(2)(D)(iv)

§ 521(b)(2)(D)(iv)

In 2025, the most used transfer pricing method (TPM) for both the sale of tangible property and the use of intangible property continued toInbe2025,

the comparable

ts method/transactional

net margin

method

was used

for 86 percent

the mostprofi

used

transfer pricing method

(TPM)

for(CPM/TNMM).

both the saleThe

of CPM/TNMM

tangible property

and

of these types of transactions.

the use of intangible property continued to be the comparable profits method/transactional net

method

(CPM/TNMM).

CPM/TNMM

was

used for

86 percent

of these

types of the operating

As inmargin

recent years,

for covered

transactionsThe

involving

tangible and

intangible

property

that used

the CPM/TNMM,

transactions.

margin (OM) is still the most common profit level indicator (PLI) used to benchmark results. It was used 57 percent of the time.

Other PLIs, such as the Berry Ratio and return on sales, made up another 20 percent. As used here, “OM” is defined as the ratio of

10

11

and

Ratio”

is defined as the

ratio of gross

profitand

to operating

expenses.

Most

services

operating

profi

t to sales,

As in

recent

years,

for“Berry

covered

transactions

involving

tangible

intangible

property

that

usedtransactions

(83 percent)

also

used

the

CPM/TNMM

with

the

OM

and

operating

profi

t-to-operating

expense

ratio

being

the

most

the CPM/TNMM, the operating margin (OM) is still the most common profit level indicator common PLIs

(used 66 percent of the time).

(PLI) used to benchmark results. It was used 57 percent of the time. Other PLIs, such as the

Berry

Ratio and return

on sales,Selection

made up

another

20Nature

percent.

As used here,

“OM” is defined

as Party Data

Sources

of Comparables,

Comparables

Criteria,

and

of Adjustments

to Comparables

or Tested

§ 521(b)(2)(D)(v-vii)

For the

APAs executed in 2025 that involved the CPM/TNMM with a North American tested party, the most widely used data source

9

Not all thewas

executed

APAs

a tested party. Whether

an APA Diff

involves

tested party

would

on the

for comparables

Standard

andinvolve

Poor’s Compustat/Capital

IQ database.

erent asources

were used

independ

other cases

(e.g., where the

transfer pricing method used.

tested party was not a North American entity or where transaction-based methods were applied). Other commonly used databases are

listed in the table below.

Table 5: Sources of Comparable Data

8

Bureau van Dijk (BvD) Orbis

Capitaline TP

Global Vantage

RoyaltySource

ktMINE

RoyaltyStat

Ace TP

In making comparability adjustments as identified in Treas. Reg. §§ 1.482-1(d)(2) and 1.482-5(c)(2)(iv), typical balance sheet adjustments were made in most cases, including, where appropriate, adjustments for payables, receivables, inventory, and fixed assets.

Not all the executed APAs involve a tested party. Whether an APA involves a tested party would depend on the transfer pricing method used.

See Treas. Reg. § 1.482-5(b)(4)(ii)(A).

11

See Treas. Reg. § 1.482-5(b)(4)(ii)(B).

9

10

April 13, 2026

820

Bulletin No. 2026–16

In addition, where appropriate, adjustments for different accounting practices were made to convert from LIFO to FIFO inventory

accounting, and a small number of cases involved the accounting reclassification of expenses, e.g., from COGS to operating expenses.

Ranges and Adjustment Mechanisms

§ 521(b)(2)(D)(viii-ix)

Most transactions covered by APAs target an interquartile range as described in Treas. Reg. § 1.482-1(e)(2)(iii)(C), a point within the

interquartile range, or another targeted arm’s length range. Where the transaction involves a royalty payment for the use of intangible

property, both specific royalty rates and ranges have been used. Where the covered transaction is the license of intangible property,

and the payment for such transfer could be a royalty based solely on external comparable uncontrolled transactions, a secondary or

confirming method, e.g., a test of the post-royalty operating margin or cost-plus mark-up, has sometimes also been used. The testing

periods of the APAs executed in 2025 were either a single year, the term of the APA only, or the term of the APA plus rollback years.

APAs executed in 2025 included several mechanisms for adjusting the tested party’s results when the results fall outside the agreed

range or do not match the point required by the APA. Examples of the mechanisms used include an adjustment bringing the tested

party’s results for a single year to either the closer edge of the range or the median of the range, an adjustment to bring the results

over the APA term to the closer edge of the range or the median of the range, or an adjustment to bring the results to a specified point

or royalty rate.

Critical Assumptions

§ 521(b)(2)(D)(v)

The model APA used by the IRS (included as Appendix 1 of this report) includes standard critical assumptions that there will be no

material changes to the taxpayer’s business or to its tax or financial accounting practices during the APA term. Some bilateral cases

have also included critical assumptions tied to the taxpayer’s profitability in a certain year or over the term of the APA. Pursuant to

§ 7.06(3) of Rev. Proc. 2015-41, APMA will cancel an APA in the event of a failure of a critical assumption unless the parties agree

to revise the APA.

Term Lengths of APAs Executed in 2025

§ 521(b)(2)(D)(x)

Table 6: Term Lengths of APAs Executed in 2025

Term Length (years)

1

2

3

4

5

6

7

8

9

10

11

15

Average

Number of APAs

2

3

4

4

41

20

15

7

4

2

2

3

6

As described in § 3.03 of Rev. Proc. 2015-41, taxpayers should request an APA term that will cover at least five prospective taxable

years and may also request that the APA be “rolled back” to cover one or more earlier taxable years, although the appropriate APA

term is decided on a case-by-case basis. Of the APAs executed in 2025, 23 percent included rollback years. A substantial number of

APAs with terms of greater than five years were initially submitted as a request for a five-year term, and the additional years were

Bulletin No. 2026–16

821

April 13, 2026

agreed to between the taxpayer and the IRS (or, in the case of a bilateral APA, between the IRS and the foreign government upon the

taxpayer’s request) to ensure a reasonable amount of prospectivity in the APA term.

Amount of Time Taken to Complete New and Renewal APAs

§ 521(b)(2)(E)

Amount of Time Taken to Complete New and Renewal APAs

Table§7:521(b)(2)(E)

Months to Complete New and Renewal APAs Executed in 2025

Table 7: Months to Complete

Unilateral New and Renewal

Bilateral APAs Executed

Unilateralin&2025

Bilateral

Unilateral

Average

Median

Average

Median

Average

Median &

Unilateral

Bilateral

Bilateral

New

39.6

39.6

50.0

46.4

49.8

45.9

Average

Median

Average

Median

Average

Median

Renewal

40.4

34.8

37.5

39.8

38.2

38.4

39.6

39.6

50.0

46.4

49.8

45.9

New &New

Renewal

40.3

37.2

44.7

41.8

44.1

41.6

Renewal

40.4

34.8

37.5

39.8

38.2

38.4

Renewal APAs

in 2025

New & Renewal Months

40.3to Complete

37.2New and44.7

41.8Executed44.1

41.6

Months to Complete New and Renewal APAs Executed in 2025

Months to Complete

50.0

New

40.0

30.0

Renewal

20.0

New &

Renewal

10.0

0.0

Average

Median

Average

Unilateral

Median

Bilateral

Type of APA

Average

Median

Unilateral &

Bilateral

Efforts to Ensure Compliance with APAs

Efforts

to Ensure Compliance with APAs

§ 521(b)(2)(F)

§ 521(b)(2)(F)

As described in § 7.02(1) of Rev. Proc. 2015-41, taxpayers are required to file annual reports to

As described in § 7.02(1) of Rev. Proc. 2015-41, taxpayers are required to file annual reports to demonstrate compliance with the

the and

terms

andofconditions

theirare

APAs.

of

termsdemonstrate

and conditions compliance

of their APAs. with

The filing

review

these annualof

reports

criticalThe

partsfiling

of the and

APA review

process. Through

annual

annual

reports

are critical

of the

APA process.

Through

annual report

review,

reportthese

review,

the APMA

Program

monitorsparts

taxpayer

compliance

with APAs

on a contemporaneous

basis.

Annualthe

report review also

provides

current

information

on the success

or problems

associated

the various

TPMs adopted in thebasis.

APA process.

APMA

Program

monitors

taxpayer

compliance

withwith

APAs

on a contemporaneous

Annual

report review also provides current information on the success or problems associated with the

Nature

of Documentation

Required

in APA

Annual

Report

various

TPMs adopted

in the

process.

§ 521(b)(2)(D)(xi)

APAs require taxpayers to file timely and complete annual reports describing their operations and demonstrating compliance with

the APA’s terms and conditions. Not every annual report will include each of the items listed in Appendix C of the Model APA; items

are required to be included where the facts demonstrate a need for such documentation. The requirements for the information to be

included in a specific APA annual report is included in Appendix C of the executed APA.

Approaches for Sharing of Currency or Other Risks

§ 521(b)(2)(D)(xii)

In appropriate cases, APAs may provide specific approaches for dealing with risks, including currency risk, such as adjustment mechanisms and/or critical assumptions.

April 13, 2026

11

822

Bulletin No. 2026–16

APPENDIX 1– Model APA

ADVANCE PRICING AGREEMENT

between

[Insert Taxpayer’s Name]

and

THE INTERNAL REVENUE SERVICE

PARTIES

The Parties to this Advance Pricing Agreement (APA) are the Internal Revenue Service (IRS) and [Insert Taxpayer’s Name], EIN

________.

RECITALS

[Insert Taxpayer Name] is the common parent of an affiliated group filing consolidated U.S. tax returns (collectively referred to as

“Taxpayer”) and is entering into this APA on behalf of itself and other members of its consolidated group.

Taxpayer’s principal place of business is [City, State]. [Insert general description of Taxpayer and other relevant parties].

This APA contains the Parties’ agreement on the best method for determining arm’s-length prices of the Covered Issues under

I.R.C. section 482, the Treasury Regulations thereunder, and any applicable tax treaties.

{If renewal, add} [Taxpayer and IRS previously entered into an APA covering taxable years ending _____ to ______, executed on

________.]

AGREEMENT

The Parties agree as follows:

1.

Covered Issues. This APA applies to the Covered Issues, as defined in Appendix A.

2.

Covered Methods. Appendix A sets forth the Covered Methods for the Covered Issues.

3.

Term. This APA applies to the APA Term, as defined in Appendix A.

4.

Operation.

5.

a.

Revenue Procedure 2015-41 governs the interpretation, legal effect, and administration of this APA.

b.

Nonfactual oral and written representations, within the meaning of sections 6.04 and 6.05 of Revenue Procedure 2015-41

(including any proposals to use particular TPMs), made in conjunction with the APA Request constitute statements made in

compromise negotiations within the meaning of Rule 408 of the Federal Rules of Evidence.

Compliance.

a.

Taxpayer must report its taxable income in an amount that is consistent with Appendix A and all other requirements of this

APA on its timely filed U.S. Return. However, if Taxpayer’s timely filed U.S. Return for any taxable year covered by this

APA (APA Year) is filed prior to, or no later than 60 days after, the effective date of this APA, then Taxpayer must report its

taxable income for that APA Year in an amount that is consistent with Appendix A and all other requirements of this APA:

(i) on a timely-filed U.S. Return, (ii) on an amended U.S. Return filed no later than 120 days after the effective date of this

APA, or (iii) by an alternative means (for example, by agreed adjustments with the IRS office with examination jurisdiction

over the taxpayer for any APA year currently under examination).

Bulletin No. 2026–16

823

April 13, 2026

b.

{Use or edit the following when U.S. Group or Foreign Group contains more than one member.} [This APA addresses the

arm’s-length nature of prices charged or received in the aggregate between Taxpayer and Foreign Participants with respect

to the Covered Issues. Except as explicitly provided, this APA does not address and does not bind the IRS with respect to

prices charged or received, or the relative amounts of income or loss realized, by particular legal entities that are members

of U.S. Group or that are members of Foreign Group.]

c.

The IRS will not reconsider any Covered Method but will instead limit any examination of Taxpayer’s treatment of Covered Issues in their U.S. Return for any APA Year to, and may require that Taxpayer establish, the following: (i) Taxpayer’s

compliance with the terms and conditions of this APA, (ii) the accuracy of material representations included in APA annual

reports submitted pursuant to this APA, and (iii) the correctness of the supporting data and computations used to apply the

Covered Method. The IRS may audit and propose adjustments to Taxpayer’s results as determined under this APA’s Covered Method without affecting the APA’s validity or applicability. Taxpayer may agree with the proposed adjustments in the

same manner as any other adjustment, in which case the IRS will assess any resulting additional tax or refund any resulting

overpayment of tax accordingly. If it does not agree with the proposed adjustment, Taxpayer may contest it through available

administrative and judicial procedures. Taxpayer must include the audit adjustments as finally determined for the purpose of

applying the Covered Method and must then make any resulting APA primary adjustments.

d.

If Taxpayer does not comply with the terms and conditions of this APA, then the IRS may:

i.

enforce the terms and conditions of this APA and make or propose allocations or adjustments under I.R.C. section 482

consistent with this APA;

ii. cancel or revoke this APA under section 7.06 of Revenue Procedure 2015-41; or

iii. revise this APA, if the Parties agree.

6.

e.

Taxpayer must timely file an Annual Report that includes a signed “penalties of perjury” declaration for each APA Year in

accordance with Appendix C and section 7.02 of Revenue Procedure 2015-41. The Annual Report may be submitted only

by electronic transmission pursuant to paragraph 15 and must include an image of an original signature or a digital signature

that uses encryption techniques to provide proof of original and unmodified documentation. Taxpayer must file the Annual

Report for all APA Years through the APA Year ending [insert year] by [insert date]. Taxpayer must file the Annual Report

for each subsequent APA Year by [insert month and day] immediately following the close of that APA Year. (If any date falls

on a weekend or holiday, the Annual Report shall be due on the next date that is not a weekend or holiday.) The IRS may

request additional information reasonably necessary to clarify or complete the Annual Report. Taxpayer will provide such

requested information within 30 days. Additional time may be allowed for good cause.

f.

The IRS will determine whether Taxpayer has complied with this APA based on Taxpayer’s U.S. Returns, the Financial

Statements, and other APA Records, for the APA Term and any other year necessary to verify compliance. For Taxpayer

to comply with this APA, {use the following or an alternative} an independent certified public accountant must render an

opinion that Taxpayer’s Financial Statements present fairly, in all material respects, Taxpayer’s financial position under

applicable generally accepted accounting standards.

g.

In accordance with section 7.04 of Revenue Procedure 2015-41, Taxpayer will (1) maintain the APA Records, and (2) make

them available to the IRS in connection with an examination under section 7.03. Compliance with this subparagraph constitutes compliance with the record-maintenance provisions of I.R.C. sections 6038A and 6038C for the Covered Issues for

any taxable year during the APA Term.

h.

The True Taxable Income within the meaning of Treasury Regulations sections 1.482-1(a)(1) and (i)(9) of a member of an

affiliated group filing a U.S. consolidated return will be determined under the I.R.C. section 1502 Treasury Regulations.

i.

{Optional for US Parent Signatories} To the extent that Taxpayer’s compliance with this APA depends on certain acts of

Foreign Group members, Taxpayer will ensure that each Foreign Group member will perform such acts.

Critical Assumptions. This APA’s critical assumptions, within the meaning of Revenue Procedure 2015-41, section 1.04, appear

in Appendix B. If any critical assumption has not been met, then Revenue Procedure 2015-41, section 7.06, governs.

April 13, 2026

824

Bulletin No. 2026–16

7.

Disclosure. An APA, any background information relating to the APA, and the taxpayer’s APA request and any supplementary

materials submitted in conjunction with the APA request are subject to various sections of the I.R.C. and U.S. competent authority treaty obligations as more fully explained in section 9 of Rev. Proc. 2015-41.

8.

Disputes. If a dispute arises concerning the interpretation of this APA, the Parties will seek a resolution by the IRS’s Director,

Treaty and Transfer Pricing Operations, to the extent reasonably practicable, before seeking alternative remedies.

9.

Materiality. In this APA the terms “material” and “materially” will be interpreted consistently with the definition of “material

facts” in Revenue Procedure 2015-41, section 7.06(4).

10. Section Captions. This APA’s section captions, which appear in italics, are for convenience and reference only. The captions do

not affect in any way the interpretation or application of this APA.

11. Terms and Definitions. Unless otherwise specified, terms in the plural include the singular and vice versa. Appendix D contains

definitions for capitalized terms not elsewhere defined in this APA.

12. Entire Agreement and Severability. This APA is the complete statement of the Parties’ agreement. The Parties will sever, delete,

or reform any invalid or unenforceable provision in this APA to approximate the Parties’ intent as nearly as possible.

13. Successor in Interest. This APA binds, and inures to the benefit of, any successor in interest to Taxpayer.

14. Notice. Any notices required by this APA or Revenue Procedure 2015-41 must be in writing. Taxpayer will send notices to the

IRS at:

Commissioner, Large Business and International Division

Internal Revenue Service

1111 Constitution Avenue, NW

SE:LB:TTPO:APMA:K:APMA Director

Washington, DC 20224

(Attention: APMA)

The IRS will send notices to the taxpayer at:

Taxpayer Corporation

Attn: Jane Doe, Sr. Vice President (Taxes)

1000 Any Road

Any City, USA 10000

(phone: __________)

15. Submission by electronic transmission. The form of electronic document transmittal will be one of the three alternatives described

below. Regardless of the transmittal mode, Taxpayer must contact APMA by email at lbi.ttpo.apma.feedback@irs.gov to initiate

the mode.

a.

Taxpayer-Licensed Secure Portal. APMA prefers to send and receive documents to/from taxpayers through a taxpayer-licensed secure portal as this provides the highest degree of protection.

b.

Email with encrypted attachments. When secure portal mode is not selected, Taxpayer may send and receive documents to

and from APMA by email. Before employing this document transmittal mode, an APMA employee will authenticate that

Taxpayer initiated the mode at the email noted above. After authentication, Taxpayer must then submit consent to transmit

encrypted documents by email in the following form:

“I consent to receive encrypted documents by email from APMA employees for the duration of this APA/MAP request.”

c.

Unencrypted email. Communication by unencrypted email is not secure, and therefore not encouraged. However, if Taxpayer chooses this mode, Taxpayer should:

i.

Exclude sensitive information, including portions of Taxpayer’s TIN or name, from the subject line and body of emails.

Bulletin No. 2026–16

825

April 13, 2026

ii. Transmit any potentially sensitive information, including personally identifiable information, only via encrypted, password-protected attachments.

The User Guide at Sign and Send Documents Electronically | Internal Revenue Service (irs.gov) contains additional information

about encrypting files and sending documents to IRS by email.

16. Effective Date and Counterparts. This APA is effective starting on the date, or later date of the dates, upon which all Parties

execute this APA. The Parties may execute this APA in counterparts, with each counterpart constituting an original.

WITNESS,

The Parties have executed this APA on the dates below.

[Taxpayer Name in all caps]

By: ___________________________

Jane Doe

Sr. Vice President (Taxes)

Date: ___________________, 202___

IRS

By: ___________________________

John M. Wall

Acting Director, APMA Program

April 13, 2026

Date: ___________________, 202___

826

Bulletin No. 2026–16

APPENDIX A

COVERED ISSUES AND COVERED METHOD

1.

Covered Issues.

[Define the Covered Issues.]

2.

APA Term.

This APA applies to Taxpayer’s taxable years ending __________ through ________ (APA Term).

3.

Covered Methods.

{Note: If appropriate, adapt language from the following examples.}

[The Tested Party is __________.]

CUP Method

The covered method is the comparable uncontrolled price (CUP) method. The Arm’s Length Range of the price charged for

_________ is between _______ and ___________ per unit.

CUT Method

The covered method is the CUT Method. The Arm’s Length Range of the royalty charged for the license of ______is

between ____% and ___ % of [Taxpayer’s, Foreign Participants’, or other specified party’s] Net Sales Revenue. [Insert

definition of net sales revenue or other royalty base.]

Resale Price Method (RPM)

The covered method is the resale price method (RPM). The Tested Party’s Gross Margin for any APA Year is defined as follows: the Tested Party’s gross profit divided by its sales revenue (as those terms are defined in Treasury Regulations sections

1.482-5(d)(1) and (2)) for that APA Year. The Arm’s Length Range is between ____% and ___ %, and the Median of the

Arm’s Length Range is ___%.

Cost Plus Method

The covered method is the cost plus method. The Tested Party’s Cost Plus Markup is defined as follows for any APA Year:

the Tested Party’s ratio of gross profit to production costs (as those terms are defined in Treasury Regulations sections

1.482-3(d)(1) and (2)) for that APA Year. The Arm’s Length Range is between ___% and___%, and the Median of the Arm’s

Length Range is___%.

CPM with Berry Ratio PLI

The covered method is the comparable profits method (CPM). The profit level indicator is a Berry Ratio. The Tested Party’s

Berry Ratio is defined as follows for any APA Year: the Tested Party’s gross profit divided by its operating expenses (as

those terms are defined in Treasury Regulations sections 1.482-5(d)(2) and (3)) for that APA Year. The Arm’s Length Range

is between ___ % and ___%, and the Median of the Arm’s Length Range is ___%

CPM using an Operating Margin PLI

The covered method is the comparable profits method (CPM). The profit level indicator is an operating margin. The Tested

Party’s Operating Margin is defined as follows for any APA Year: the Tested Party’s operating profit divided by its sales revenue (as those terms are defined in Treasury Regulations section 1.482-5(d)(1) and (4)) for that APA Year. The Arm’s Length

Range is between ____% and ___ %, and the Median of the Arm’s Length Range is ___.

CPM using a Three-year Rolling Average Operating Margin PLI

Bulletin No. 2026–16

827

April 13, 2026

The covered method is the comparable profits method (CPM). The profit level indicator is an operating margin. The Tested

Party’s Three-Year Rolling Average operating margin is defined as follows for any APA Year: the sum of the Tested Party’s

operating profit (within the meaning of Treasury Regulations section 1.482-5(d)(4) for that APA Year and the two preceding

years, divided by the sum of its sales revenue (within the meaning of Treasury Regulations section 1.482-5(d)(1)) for that

APA Year and the two preceding years. The Arm’s Length Range is between ____% and ____%, and the Median of the

Arm’s Length Range is ___%.

Residual Profit Split Method

The covered method is the residual profit split method. [Insert description of routine profit level determinations and residual

profit-split mechanism].

[Insert additional provisions as needed.]

4.

Application of Covered Method.

For any APA Year, if the results of Taxpayer’s actual transactions produce a [price per unit, royalty rate for the Covered

Issues] [or] [Gross Margin, Cost Plus Markup, Berry Ratio, Operating Margin, Three-Year Rolling Average Operating Margin for the Tested Party] within the Arm’s Length Range, then the amounts reported on Taxpayer’s U.S. Return must clearly

reflect such results.

For any APA year, if the results of Taxpayer’s actual transactions produce a [price per unit, royalty rate] [or] [Gross Margin,

Cost Plus Markup, Berry Ratio, Operating Margin, Three-Year Rolling Average Operating Margin for the Tested Party]

outside the Arm’s Length Range, then amounts reported on Taxpayer’s U.S. Return must clearly reflect an adjustment that

brings the [price per unit, royalty rate] [or] [Tested Party’s Gross Margin, Cost Plus Markup, Berry Ratio, Operating Margin,

Three-Year Rolling Average Operating Margin] to the Median.

For purposes of this Appendix A, the “results of Taxpayer’s actual transactions” means the results reflected in Taxpayer’s

and Tested Party’s books and records as computed under applicable generally accepted accounting standards [insert another

relevant accounting standard if applicable], with the following adjustments:

(a) [The fair value of stock-based compensation as disclosed in the Tested Party’s audited Financial Statements shall be

treated as an operating expense]; and

(b) To the extent that the results in any prior APA Year are relevant (for example, to compute a multi-year average), such

results shall be adjusted to reflect the amount of any adjustment made for that prior APA Year under this Appendix A.

5.

Conforming Adjustments

If Taxpayer makes an adjustment under paragraph 4 of this Appendix A (an “APA primary adjustment”, see Revenue Procedure 2015-41, section 7.01(1)), a conforming adjustment will be required as specified in Revenue Procedure 2015-41, section 7.01(2)(a). For this purpose, if there are multiple APA primary adjustments for an APA Year, those adjustments will first

be netted to derive a net APA primary adjustment, for which a conforming adjustment will be required. In some cases, the

conforming adjustment can be accomplished by a repatriation of funds as specified in Revenue Procedure 2015-41, section

7.01(2). Except as specified in this APA, conforming adjustments (including any repatriation of funds) are governed by the

applicable rules under the I.R.C., including Rev. Proc. 99-32, 1992-2 C.B. 296, or successor guidance.

[Per Revenue Procedure 2015-41, section 7.01(2)(d), the APA “will specify the terms of conforming adjustments, including, but not limited to, the terms of any repatriation of funds.” Also, any deviation from the treatment under the Code (e.g.,

no interest on repatriation payments) must be specified in the APA and must be pursuant to a competent authority resolution

(see Revenue Procedure 2015-41, section 7.01(2)(b)).]

April 13, 2026

828

Bulletin No. 2026–16

APPENDIX B

CRITICAL ASSUMPTIONS

This APA’s critical assumptions are:

1.

The business activities, functions performed, risks assumed, assets employed, and financial and tax accounting methods and classifications [and methods of estimation] of Taxpayer in relation to the Covered Issues will remain materially the same as described

or used in Taxpayer’s APA Request. A mere change in business results will not be a material change.

[Insert additional provisions as needed.]

Bulletin No. 2026–16

829

April 13, 2026

APPENDIX C

APA RECORDS AND ANNUAL REPORT

APA Records

The APA Records will consist of all documents listed below for inclusion in the Annual Report, as well as all documents, notes, work

papers, records, or other writings that support the information provided in such documents.

Annual Report

The Annual Report will include:

1.

A properly completed APA Annual Report Summary in the form of Appendix E to this APA;

2.

A table of contents, organized as follows; and

3.

Statements that fully identify, describe, analyze, and explain:

a.

All material differences between the U.S. Group’s business operations (including functions, risks assumed, markets, contractual terms, economic conditions, property, services, and assets employed) during the APA Year from the business operations

described in the APA Request. If there have been no material differences, the Annual Report will include a statement to that

effect.

b.

All material differences between the U.S. Group’s accounting methods and classifications, and methods of estimation used

during the APA Year, from those described or used in the APA Request. If any change was made to conform to changes in

applicable generally accepted accounting standards (or other relevant accounting standards) Taxpayer will specifically identify the change. If there has been no material change in accounting methods and classifications or methods of estimation, the

Annual Report will include a statement to that effect.

c.

Any change to the Taxpayer notice information in paragraph 14 of this APA.

d.

Any failure to meet any critical assumption. If there has been no failure, the Annual Report will include a statement to that

effect.

e.

Whether or not material information submitted while the APA Request was pending is discovered to be false, incorrect, or

incomplete.

f.

Any change to any entity classification for federal income tax purposes (including any change that causes an entity to be

disregarded for federal income tax purposes) of any Worldwide Group member that is a party to the Covered Issues or is

otherwise relevant to the covered method.

g.

The following regarding any APA primary adjustments made under Appendix A for the APA Year:

i.

The amounts of any APA primary adjustments;

ii. The circumstances that led to such APA primary adjustments being necessary;

iii. A calculation of the net APA primary adjustment as defined in Appendix A;

iv. A complete description of the means by which the conforming adjustment (see Appendix A) is accomplished, including:

A. a description of any accounts payable established in connection with a repatriation of funds pursuant to paragraph

5 of Appendix A and section 7.01(2) of Revenue Procedure 2015-41, including the entities involved and when the

payables are established;

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B. a description of any amounts paid or deemed paid (including amounts paid in satisfaction of such accounts payable), that specifies the entities involved, when the amounts are paid or deemed paid, and by what means any

amounts are actually paid;

C. the character (such as capital, ordinary, income, expense, dividend, contribution to capital) and country source of

any payments and deemed payments, and the specific affected line item(s) of any affected U.S. Return.

h.

The amounts, description, reason for, and financial analysis of any book-tax difference relevant to the covered method for

the APA Year, as reflected on Schedule M-1 or Schedule M-3 of the U.S. Return for the APA Year.

i.

Whether Taxpayer contemplates requesting, or has requested, to renew, modify, or cancel the APA.

4.

The Financial Statements, and any necessary account detail to show compliance with the covered method, including consolidating financial statements, segmented financial data, records from the general ledger, or similar information if the assets, liabilities,

income, or expenses relevant to showing compliance with the covered method are a subset of the assets, liabilities, income, or

expenses presented in the Financial Statements.

5.

{Use the following or the alternative prescribed by paragraph 5(f) of this APA:} A copy of the independent certified public

accountant’s opinion required by paragraph 5(f) of this APA.

6.

A financial analysis that reflects Taxpayer’s covered method calculations for the APA Year. The calculations must reconcile with

and reference the information required under item 4 above in sufficient account detail to allow the IRS to determine whether

Taxpayer has complied with the covered method.

7.

An organizational chart for the Worldwide Group, revised annually to reflect all ownership or structural changes of entities that

are parties to the Covered Issues or are otherwise relevant to the covered method.

8.

A copy of the APA and any amendment.

9.

A penalty of perjury statement, executed in accordance with Revenue Procedure 2015-41, section 7.02(8) and (9).

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APPENDIX D

DEFINITIONS

The following definitions control for all purposes of this APA. The definitions appear alphabetically below:

Term

Annual Report

APA

APA Records

APA Request

APA Year

Applicable generally accepted

accounting standards

Covered Issue(s)

Covered Method(s)

Financial Statements

Foreign Group

Foreign Participants

I.R.C.

Pub. L. 106-170

Revenue Procedure 2015-41

Transfer Pricing Method (TPM)

U.S. GAAP

U.S. Group

U.S. Return

Worldwide Group

April 13, 2026

Definition

An APA annual report within the meaning of Revenue Procedure 2015-41, sections 1.04 and

7.02.

This Advance Pricing Agreement, which is an “advance pricing agreement” within the

meaning of Revenue Procedure 2015-41, section 1.04.

The records specified in Revenue Procedure 2015-41, section 7.04 and Appendix C of this

APA.

Taxpayer’s request for this APA dated _________, including any amendments or

supplemental or additional information thereto.

This term is defined in Appendix A of this APA.

As the context requires, United States Generally Accepted Accounting Principles,

International Financial Accounting Standards, or similar pronouncements to which reporting

enterprises are obliged to conform in preparing financial statements for investors, creditors,

and governmental agencies.

This term is defined in Appendix A of this APA.

Transfer Pricing Method described in Appendix A of this APA.

As the context requires, those financial statements prepared in accordance with applicable

generally accepted accounting standards, and any necessary account detail to show

compliance with the covered method, including consolidating financial statements,

segmented financial data, records from the general ledger, or similar information if the

assets, liabilities, income, or expenses relevant to showing compliance with the covered

method are a subset of the assets, liabilities, income, or expenses presented in the Financial

Statements.

Worldwide Group members that are not U.S. persons.

[name the foreign entities involved in Covered Issues].

The Internal Revenue Code of 1986, 26 U.S.C., as amended.

The Ticket to Work and Work Incentives Improvement Act of 1999.

Rev. Proc. 2015-41, 2015-35 IRB 263.

A transfer pricing method within the meaning of Treasury Regulations section 1.482-1(b).

U.S. generally accepted accounting principles.

Worldwide Group members that are U.S. persons.

For each taxable year, the “returns with respect to income taxes under subtitle A” that

Taxpayer must “make” in accordance with I.R.C. section 6012. {Or substitute for

partnership: For each taxable year, the “return” that Taxpayer must “make” in accordance

with I.R.C. section 6031.}

Taxpayer and all organizations, trades, businesses, entities, or branches (whether or not

incorporated, organized in the United States, or affiliated) owned or controlled directly or

indirectly by the same interests.

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Bulletin No. 2026–16

APPENDIX E

APA ANNUAL REPORT SUMMARY FORM

The APA Annual Report Summary on the next page is a required APA Record. The APA Team Leader supplies some of the information requested on the form. Taxpayer is to supply the remaining information requested by the form and submit the form as part of

its Annual Report.

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Internal Revenue Service

Large Business and International Division

Treaty & Transfer Pricing Operations

Advance Pricing Mutual Agreement Program

APMA Case No.

Reviewer

Team Leader

Economist

Other APA Team Members

APA Information

U.S. Taxpayer’s Name

U.S. Taxpayer’s EIN

U.S. Taxpayer’s NAICS

Unilateral/Bilateral/Multilateral

Original or Renewal

APA Common Name, if any

APA Request Filing Date

Date APA Executed

APA Term (date-to-date, inclusive)

Foreign Country(ies) Involved

Annual Report Due Dates for years ending on or before [date]:

Annual Report Due Dates for other years: [last month of tax year] 15 following close of year

Covered Methods Summary Description

(e.g., CPM, operating margin 2%-5%)

Taxpayer’s Principal Representative

APA Annual Report Information

Year(s) covered by this Annual Report

Issues for APMA’s special attention (or “None”)

Taxpayer Notice Person

If necessary, include a

current Form 2848 for the

Notice Person

Current Representative, if any

Include a current Form 2848

for the representative

Name

Title

Address

City/State/Zip

Phone/Fax

Email

Name

Title

Address

City/State/Zip

Phone/Fax

Email

Date Annual Report Filed (to be filled in by APMA):

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Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

­effect:

Amplified describes a situation where

no change is being made in a prior published position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus,

if an earlier ruling held that a principle

applied to A, and the new ruling holds that

the same principle also applies to B, the

earlier ruling is amplified. (Compare with

modified, below).

Clarified is used in those instances

where the language in a prior ruling is

being made clear because the language

has caused, or may cause, some confusion. It is not used where a position in a

prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously published ruling and points out an essential

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.

This term is most commonly used in a ruling

that lists previously published rulings that

are obsoleted because of changes in laws or

regulations. A ruling may also be obsoleted

because the substance has been included in

regulations subsequently adopted.

Revoked describes situations where the

position in the previously published ruling

is not correct and the correct position is

being stated in a new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a

period of time in separate rulings. If the

new ruling does more than restate the substance of a prior ruling, a combination of

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously

published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

which a list, such as a list of the names of

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations

to show that the previous published rulings will not be applied pending some

future action such as the issuance of new

or amended regulations, the outcome of

cases in litigation, or the outcome of a

Service study.

Abbreviations

The following abbreviations in current

use and formerly used will appear in

material published in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

E.O.—Executive Order.

ER—Employer.

Bulletin No. 2026–16

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contributions Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

i

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

April 13, 2026

Numerical Finding List1

Revenue Procedures:—Continued

2026-1, 2026-04 I.R.B. 402

2026-2, 2026-05 I.R.B. 447

2026-3, 2026-06 I.R.B. 518

2026-4, 2026-06 I.R.B. 533

2026-5, 2026-07 I.R.B. 540

2026-6, 2026-10 I.R.B. 634

2026-7, 2026-11 I.R.B. 697

2026-8, 2026-16 I.R.B. 813

2026-5, 2026-01 I.R.B. 258

2026-6, 2026-02 I.R.B. 314

2026-7, 2026-02 I.R.B. 316

2026-8, 2026-04 I.R.B. 380

2026-9, 2026-04 I.R.B. 393

2026-10, 2026-04 I.R.B. 394

2026-12, 2026-07 I.R.B. 535

2026-13, 2026-09 I.R.B. 563

2026-11, 2026-12 I.R.B. 707

2026-15, 2026-13 I.R.B. 729

2026-16, 2026-13 I.R.B. 733

2026-17, 2026-15 I.R.B. 805

Notices:

Revenue Rulings:

2026-2, 2026-02 I.R.B. 304

2026-3, 2026-02 I.R.B. 307

2026-5, 2026-02 I.R.B. 309

2026-6, 2026-02 I.R.B. 313

2026-1, 2026-04 I.R.B. 365

2026-8, 2026-04 I.R.B. 368

2026-10, 2026-04 I.R.B. 378

2026-11, 2026-06 I.R.B. 491

2026-12, 2026-06 I.R.B. 496

2026-13, 2026-06 I.R.B. 499

2026-9, 2026-07 I.R.B. 534

2026-7, 2026-11 I.R.B. 637

2026-14, 2026-11 I.R.B. 654

2026-15, 2026-11 I.R.B. 658

2026-16, 2026-11 I.R.B. 685

2026-17, 2026-12 I.R.B. 698

2026-4, 2026-13 I.R.B. \726

2026-19, 2026-15 I.R.B. \797

2026-20, 2026-15 I.R.B. \800

2026-22, 2026-15 I.R.B. \802

2026-23, 2026-15 I.R.B. \804

2026-1, 2026-02 I.R.B. 299

2026-2, 2026-03 I.R.B. 342

2026-3, 2026-06 I.R.B. 485

2026-4, 2026-06 I.R.B. 487

2026-5, 2026-08 I.R.B. 542

2026-6, 2026-11 I.R.B. 635

2026-7, 2026-15 I.R.B. 791

2026-8, 2026-16 I.R.B. 812

Bulletin 2026–16

Announcements:

Treasury Decisions:

10042, 2026-03 I.R.B. 320

10041, 2026-04 I.R.B. 360

10039, 2026-05 I.R.B. 403

10040, 2026-05 I.R.B. 416

10043, 2026-15 I.R.B. 793

Proposed Regulations:

REG-101952-24, 2026-03 I.R.B. 345

REG-110519-25, 2026-03 I.R.B. 353

REG-132251-11; REG-134219-08,

2026-03 I.R.B. 358

REG-103430-24, 2026-05 I.R.B. 447

REG-112829-25, 2026-05 I.R.B. 452

REG-113515-25, 2026-05 I.R.B. 455

REG-121244-23, 2026-09 I.R.B. 579

REG-105064-25, 2026-13 I.R.B. 735

REG-108921-25, 2026-13 I.R.B. 756

REG-117002-25, 2026-13 I.R.B. 761

REG-117270-25, 2026-13 I.R.B. 772

REG-117298-21, 2026-14 I.R.B. 784

Revenue Procedures:

2026-1, 2026-01 I.R.B. 1

2026-2, 2026-01 I.R.B. 119

2026-3, 2026-01 I.R.B. 143

2026-4, 2026-01 I.R.B. 160

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin

2024–52, dated December 22, 2024.

1

April 13, 2026

ii

Bulletin No. 2026–16

Finding List of Current Actions on

Previously Published Items1

Bulletin 2026–16

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin

2024–52, dated December 22, 2024.

1

Bulletin No. 2026–16

iii

April 13, 2026

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue

Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,

we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page

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