Bulletin No. 2025–15

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HIGHLIGHTS

OF THIS ISSUE

Bulletin No. 2025–15

April 7, 2025

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

Announcement 2025-13, page 1392.

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

Finding Lists begin on page ii.

twenty-sixth report describes the experience, structure, and

activities of the APMA Program during calendar year 2024.

INCOME TAX

Rev. Rul. 2025-8, page 1390.

Federal rates; adjusted federal rates; adjusted federal longterm rate, and the long-term tax exempt rate. For purposes

of sections 382, 1274, 1288, 7872 and other sections of

the Code, tables set forth the rates for April 2025.

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 7, 2025

Bulletin No. 2025–15

Part I

Section 1274.—

Determination of Issue

Price in the Case of Certain

Debt Instruments Issued for

Property

(Also Sections 42, 280G, 382, 467, 468, 482, 483,

1288, 7520, 7872.)

Rev. Rul. 2025-8

This revenue ruling provides various

prescribed rates for federal income tax

Annual

AFR

110% AFR

120% AFR

130% AFR

4.16%

4.58%

5.00%

5.43%

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

4.21%

4.64%

5.06%

5.49%

6.36%

7.43%

AFR

110% AFR

120% AFR

130% AFR

4.61%

5.08%

5.54%

6.02%

Short-term adjusted AFR

Mid-term adjusted AFR

Long-term adjusted AFR

April 7, 2025

purposes for April 2025 (the current

month). Table 1 contains the shortterm, mid-term, and long-term applicable federal rates (AFR) for the current

month for purposes of section 1274(d)

of the Internal Revenue Code. Table 2

contains the short-term, mid-term, and

long-term adjusted applicable federal

rates (adjusted AFR) for the current

month for purposes of section 1288(b).

Table 3 sets forth the adjusted federal long-term rate and the long-term

tax-exempt rate described in section

382(f). Table 4 contains the appropri-

ate percentages for determining the

low-income housing credit described in

section 42(b)(1) for buildings placed in

service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service

after July 30, 2008, shall not be less

than 9%. Finally, Table 5 contains the

federal rate for determining the present

value of an annuity, an interest for life

or for a term of years, or a remainder or

a reversionary interest for purposes of

section 7520.

REV. RUL. 2025-8 TABLE 1

Applicable Federal Rates (AFR) for April 2025

Period for Compounding

Semiannual

Quarterly

Short-term

4.12%

4.10%

4.53%

4.50%

4.94%

4.91%

5.36%

5.32%

Mid-term

4.17%

4.15%

4.59%

4.56%

5.00%

4.97%

5.42%

5.38%

6.26%

6.21%

7.30%

7.23%

Long-term

4.56%

4.53%

5.02%

4.99%

5.47%

5.43%

5.93%

5.89%

Annual

3.15%

3.20%

3.49%

REV. RUL. 2025-8 TABLE 2

Adjusted AFR for April 2025

Period for Compounding

Semiannual

3.13%

3.17%

3.46%

1390

Monthly

4.09%

4.49%

4.89%

5.30%

4.13%

4.55%

4.95%

5.36%

6.18%

7.19%

4.52%

4.97%

5.41%

5.86%

Quarterly

3.12%

3.16%

3.45%

Monthly

3.11%

3.15%

3.44%

Bulletin No. 2025–15

REV. RUL. 2025-8 TABLE 3

Rates Under Section 382 for April 2025

Adjusted federal long-term rate for the current month

Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal

long-term rates for the current month and the prior two months.)

3.49%

3.67%

REV. RUL. 2025-8 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for April 2025

Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after

July 30, 2008, shall not be less than 9%.

Appropriate percentage for the 70% present value low-income housing credit

8.02%

Appropriate percentage for the 30% present value low-income housing credit

3.44%

REV. RUL. 2025-8 TABLE 5

Rate Under Section 7520 for April 2025

Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,

or a remainder or reversionary interest

Section 42.—Low-Income

Housing Credit

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2025. See Rev. Rul. 2025-8, page 1390.

Section 280G.—Golden

Parachute Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2025. See Rev. Rul. 2025-8, page 1390.

Section 382.—Limitation

on Net Operating Loss

Carryforwards and

Certain Built-In Losses

Following Ownership

Change

The adjusted applicable federal long-term rate

is set forth for the month of April 2025. See Rev.

Rul. 2025-8, page 1390.

Section 467.—Certain

Payments for the Use of

Property or Services

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2025. See Rev. Rul. 2025-8, page 1390.

Section 468.—Special

Rules for Mining and Solid

Waste Reclamation and

Closing Costs

The applicable federal short-term rates are set

forth for the month of April 2025. See Rev. Rul.

2025-8, page 1390.

Section 482.—Allocation

of Income and Deductions

Among Taxpayers

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2025. See Rev. Rul. 2025-8, page 1390.

5.00%

Section 483.—Interest on

Certain Deferred Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2025. See Rev. Rul. 2025-8, page 1390.

Section 1288.—Treatment

of Original Issue Discount

on Tax-Exempt Obligations

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of

April 2025. See Rev. Rul. 2025-8, page 1390.

Section 7520.—Valuation

Tables

The applicable federal mid-term rates are set

forth for the month of April 2025. See Rev. Rul.

2025-8, page 1390.

Section 7872.—Treatment

of Loans With BelowMarket Interest Rates

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2025. See Rev. Rul. 2025-8, page 1390.

Bulletin No. 2025–15

1391

April 7, 2025

Part IV

Announcement and Report Concerning Advance Pricing Agreements

Announcement 2025-13

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 2023 separately. This twenty-sixth report describes the experience, structure, and activities of the APMA Program

during calendar year 2024. 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 2024, including types of transactions

covered, transfer pricing methods used, and completion time.

John M. Wall

Director, APMA Program

April 7, 2025

1392

Bulletin No. 2025–15

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

[Pub. L. 106-170 § 521(b)(2)(A)]

In February 2012, the former APA Program was moved from the Office of Chief Counsel to the Office of Transfer Pricing Operations1

within the Large Business and International Division of the IRS and combined with the U.S. Competent Authority staff responsible

for transfer pricing cases, thereby forming the APMA Program (APMA).

As of December 31, 2024, APMA’s APA cases were handled by a staff of 126, comprising 76 team leaders, 35 economists, 12 managers, and 3 assistant directors.2 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, 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 2017, Transfer Pricing Operations became Treaty & Transfer Pricing Operations (“TTPO”).

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.

Bulletin No. 2025–15

1393

April 7, 2025

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 1991-19993

Unilateral

Filed 2000-2023

692

Filed 1991-1999

Filed in 2024

Filed 2000-2023

692

Total Filed 1991-2024

Filed in 2024

Total Filed 1991-2024

Bilateral

Multilateral

Bilateral

Multilateral

2,143

142

2,143

142

Total

401

Total

2,885

401

169

2,885

3,455

169

3,455

Applications Filed

2015-2024

250

200

150

100

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Bilateral APAs

Filed by Country 2024

Netherlands All Other Countries

Korea

Italy

France

Germany

Mexico

Japan

32%

India

26%

Canada

10%

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

of bilateral

requeststhereceived

incomplete

2024 perapplications

foreign country.

As of

December

31, of

2024,

APMA

hadreceived in

The charts

above illustrate

number of

filed per year

and

the percentage

bilateral

requests

2024 also

per foreign

country.

As offee

December

2024,

APMA

received 42 user

filings that were

not yet accompanied

by a

received

42 user

filings31,

that

were

not had

yet also

accompanied

by afee

substantially

complete

APA

substantially

complete

APA

application,

addition

the

169

complete

APA

applications.

application, in addition to the 169 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.

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.

April 7, 2025

1394

Bulletin No. 2025–15

Table 2: Executed4 and Pending APAs

§ 521(b)(2)(C)(ii-vi)

Table 2: Executed and Pending APAs

§ 521(b)(2)(C)(ii-vi)

Unilateral

Total Executed 1991-2023

721

Total Executed 1991-2023

721

Total Executed in 2024

Total Executed 1991-2024

734

Total Executed 1991-2024

734

Total Pending as of 12/31/2024

Renewals Executed in 20245

Total Pending as of 12/31/2024

Renewals6Executed in 20245

Renewals Pending as of 12/31/2024

Renewals Pending6 as of 12/31/2024

Bilateral

Multilateral

485

Bilateral

Multilateral

1,679

119

1,798

218

485

218

Total

Total 2,424

2,424

142

2,566

560

267267

APAs Executed

2015-2024

160

140

120

100

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

United Kingdom

Switzerland

France

Netherlands

Germany

Mexico

Korea

5% Canada

Bilateral APAs

Executed by Country 2024

All Other Countries

Italy

11%

India

29%

Japan

23%

In 2024, the percentage of APA renewals executed increased (58 percent of all APAs executed in

2024

47 of

percent

of all APAs

executed

above illustrate

trends

the of all APAs

In 2024,

theversus

percentage

APA renewals

executed

increasedin

(582023).

percentThe

of allcharts

APAs executed

in 2024 versus

47 in

percent

number

APAs

executed

per

year

and

the

countries

involved

the

bilateral

APAs

that

were

executed in 2023). 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 2024.

executed

in 2024.

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

The number of renewals executed is included in the total number of APAs executed during the year.

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 executed is included in the total number of APAs executed during the year.

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

Bulletin No. 2025–15

1395

April 7, 2025

Pending APAs

2015-2024

600

500

400

300

200

100

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

All Other Countries

16%

Italy

United Kingdom

Germany

Korea

5% Mexico

Pending Bilateral APAs

by Country

Japan

28%

India

22%

Canada

13%

topillustrates,

chart illustrates,

the

of pending

requests

increased

relative

to As of December 31,

As theAs

topthe

chart

the number

of number

pending requests

increased

slightly

relative toslightly

December

31, 2023.

As of

December

31, 2024,

oforthe

pending bilateral APA requests

2024,December

half of the pending

bilateral

APA

requests involved

eitherhalf

Japan

India.

involved either Japan or India.

Table 3: APAs Revoked or Cancelled and Applications Withdrawn

§ 521(b)(2)(C)(vii)

Table 3: APAs Revoked or Cancelled and Applications Withdrawn

§ 521(b)(2)(C)(vii)

Unilateral

Revoked

or Cancelled

1991-20001991-20007

Revoked

or Cancelled

Revoked

Cancelled

2001-2023

Revoked or Cancelled 2001-2023

Revoked

or Cancelled

in 2024 in 2024

Revoked

or Cancelled

Total Revoked or Cancelled 1991-2024

Unilateral

Bilateral

Multilateral

168168

15 15

Total Revoked or Cancelled 1991-2024

Withdrawn

1991-2000

Withdrawn

1991-2000

Withdrawn

2001-2023

Withdrawn

2001-2023

Withdrawn

in 2024 in 2024

Withdrawn

1991-2024

Withdrawn

1991-2024

Total

1010

1111

4949

248

1717

314

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.

See supra note 7.

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.

See supra note 7.

April 7, 2025

1396

Bulletin No. 2025–15

Table 4: APAs Executed in 2024 by Industry

§ 521(b)(2)(C)(viii)

Table 4: APAs Executed in 2024 by Industry

§ 521(b)(2)(C)(viii)

Industry

Table 4: APAs Executed

in 2024 by Industry

Manufacturing

521(b)(2)(C)(viii)

Wholesale/Retail Trade

Wholesale/Retail

Trade

Industry

Services

Manufacturing

Management

Wholesale/Retail

Trade

Finance, Insurance and Real Estate

Finance,

Insurance and Real Estate

Services

All Other Industries

All

Other Industries

Management

Finance, Insurance and Real Estate

APAs Executed

All Other Industries

in 2024 by Industry

APAs Executed

in 2024 by Industry

Manufacturing

30%

Manufacturing

30%

All Other Industries

Finance, Insurance and Real Estate

All Other Industries

Finance, Insurance and Real Estate

4a: Manufacturing

APAs

in 2024

TableTable

4a: Manufacturing

APAs Executed

in Executed

2024

Wholesale/Retail

Trade

27%

Wholesale/Retail

Trade

27%

Services

20%

Services

20%

Management

11%

Management

11%

Type of Manufacturing

Transportation

Type ofEquipment

Manufacturing

Table

4a: Manufacturing

APAs Executed in 2024

Computer

and

Electronic

Product

Transportation Equipment

Type of Manufacturing

Chemical

Computer

and Electronic Equipment

Product

Transportation

Miscellaneous

Computer and Electronic Product

Chemical

All

Other

Manufacturing

Chemical

Miscellaneous

All Other

Manufacturing

Type of Manufacturing APAs 5

All Other Manufacturing

Executed in 2024

Type of Manufacturing APAs

Computer and Electronic

Executed in 2024

Product

24%

Computer and Electronic

Product

24%

Chemical

16%

Chemical

Miscellaneous

16%

Miscellaneous

16% All Other

Transportation

Manufacturing

Equipment

12%

32%

All

Other

Transportation

Manufacturing

Equipment

12%

32%

Industries in the Miscellaneous Manufacturing subsector (NAICS Code 339) make a wide range of products that

cannot readily be classified in specific NAICS manufacturing subsectors.

Industries

9 in the Miscellaneous Manufacturing subsector (NAICS Code 339) make a wide range of products that cannot readily be classified in specific NAICS manufacturing subsectors.

Industries in the Miscellaneous Manufacturing subsector6(NAICS Code 339) make a wide range of products that

cannot readily be classified in specific NAICS manufacturing subsectors.

Bulletin No. 2025–15

1397

April 7, 2025

Table 4b: Wholesale/Retail Trade APAs Executed in 2024

Type of Wholesale/Retail Trade

Merchant Wholesalers, Durable Goods

Merchant Wholesalers, Nondurable Goods

Clothing and Clothing Accessories Stores

All Other Wholesalers

All Other

Wholesalers

13%

Type of Wholesale/Retail Trade APAs

Executed in 2024

Merchant

Wholesalers, Durable

Goods

54%

Clothing and

Clothing Accessories

Stores

10%

Merchant

Wholesalers,

Nondurable Goods

23%

April 7, 2025

1398

Bulletin No. 2025–15

Part III. General Descriptions of APAs Executed in 2024

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

Part III. General Descriptions of APAs Executed in 2024

Part

III. General

Descriptions

of APAs Executed

[Pub.

L. 106-170

§ 521(b)(2)(D)

and (E)]in 2024

Nature of the Relationships

§ 521(b)(2)(D)(i)

Nature

of the Relationships

Nature of the Relationships

§ 521(b)(2)(D)(i)

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

Relationships between

Controlled Parties

Relationships between

Controlled Parties

U.S. Parent &

Non-U.S.

U.S.

Parent &

Subsidiary

Non-U.S.

37%

Subsidiary

37%

Non-U.S. Parent &

U.S. Subsidiary

Non-U.S.

Parent &

56%

U.S. Subsidiary

56%

All Other Relationships

Sister Companies

As in prior years, more than half of the APAs executed in 2024 involved transactions between

non-U.S. parents and U.S. subsidiaries.

As inAs

prior

thanmore

half ofthan

the APAs

in 2024executed

involved transactions

between non-U.S.

parents

and U.S. subsidiaries.

inyears,

priormore

years,

half executed

of the APAs

in 2024 involved

transactions

between

non-U.S.

and U.S.

subsidiaries.

Covered parents

Transactions,

Functions

and Risks, and Tested Parties

Covered Transactions, Functions and Risks, and Tested Parties

§ 521(b)(2)(D)(ii-iii)

Covered Transactions, Functions and Risks, and Tested Parties

§ 521(b)(2)(D)(ii-iii)

Types of Covered Transactions

Sale of Tangible

Types of Covered Transactions

All Other Types of

Property into the U.S.

Transactions

Sale of Tangible

Sale of22%

Tangible

All Other

2%Types of

Property into the U.S. Property from the

Transactions

Sale ofU.S.

Tangible

22%

Property

from the

11%

Provision of Services by a

U.S.

Non-U.S. Entity

Use of Intangible Property

11%

Provision of

Services by a

25%

by a U.S. Entity

Non-U.S. Entity

Use of Intangible

16% Property

25% Provision of Services

by a Property

U.S. Entity

Use of Intangible

16%

by a U.S. Entity

a Non-U.S. Entity

Provision18%

of Services

Use of Intangible

6% Property by

by a U.S. Entity

a Non-U.S. Entity

18%

in APAs

executed

involve

saleorof

the transactions

Most Most

of the of

transactions

covered incovered

APAs executed

in 2024

involvein

the2024

sale of

tangiblethe

goods

thetangible

provisiongoods

of services. Twenty-twoorpercent

the

transactions

involve

the

use

intangible

property,

which

can

among

the

most

challenging

transactions in

the provision of services.

Twenty-two percent of the transactions involve the use of intangible

covered

APAs

executed

2024

involve

the

sale

tangible

goods

Most

the

transactions

APMA’s

inventory.

property, which can be among the most challenging transactions in APMA’s inventory.

or the provision of services. Twenty-two percent of the transactions involve the use of intangible

In theproperty,

majority ofwhich

APAs, can

the covered

transactions

involve

numerous transactions

business functions

and risks. For

instance, with respect to funcbe among

the most

challenging

in APMA’s

In the majority

of APAs,

the covered

transactions

involve numerous

businessinventory.

functions and risks.

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

Forininstance,

with and

respect

to functions,

APAsthe

involving

manufactured

products typically

involve support

engages

product

design

engineering,

manufactures

product,

markets

and distributes

product, and

In the

majority

of APAs,

the covered

transactions

involve

numerous

businessthefunctions

andperforms

risks.

functions such as legal, finance, and human resources. Regarding risks, the controlled group may assume a variety of risks, including

For

instance,

with

respect

functions,

APAs

involving

manufactured

products

typically

involve

market

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

APAs often cover more than one type of transaction.

evaluation process, a significant amount of time and effort is devoted to understanding how functions and risks are allocated among

the controlled

groupcover

of companies

that

aretype

party

the covered transactions.

For methods requiring the selection of a tested party, the

APAs often

more than

one

of to

transaction.

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

APAs often cover more than one type of transaction.

Bulletin No. 2025–15

1399

April 7, 2025

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

U.S. Distributor

39%

Non-U.S. Distributor

All Other Types of

Tested Parties

U.S. Service Provider

U.S. Manufacturer

12%

Non-U.S. Service

Provider

31%

Consistent with prior years, U.S. distributors, U.S. manufacturers, and U.S. service providers

Consistent

with prior

years, U.S.

distributors,

manufacturers,

U.S.i.e.,

service

2024,

59 providers

percent. combined, comprised a majority of

combined,

comprised

a majority

ofU.S.

tested

parties11 inand

tested parties11 in 2024, i.e., 59 percent.

Transfer Pricing Methods Used

§ 521(b)(2)(D)(iv)

In 2024,

thecommonly

most commonly

used

transfer

pricing

both theproperty

sale ofand

tangible

In 2024,

the most

used transfer

pricing

method

(TPM)method

for both(TPM)

the salefor

of tangible

the use of intangible

property

continued

be the

comparable

profitsproperty

method/transactional

(CPM/TNMM).

property

andtothe

use

of intangible

continuednet

tomargin

be themethod

comparable

profits The CPM/TNMM was used

for 78method/transactional

percent of these types of net

transactions.

margin method (CPM/TNMM). The CPM/TNMM was used for 78

percent of these types of transactions.

As in recent years, for covered transactions involving tangible and intangible property that used the CPM/TNMM, the operating margin (OM) is still the most common profit level indicator (PLI) used to benchmark results. It was used 72 percent of the time. Other

years,

transactions

involving

tangible

and intangible

property

used

PLIs,As

suchinasrecent

the Berry

Ratiofor

andcovered

mark up on

total costs, made

up the other

28 percent.

As used here,

“OM” isthat

defined

as the ratio of

the CPM/TNMM,

the“Berry

operating

still

most

profit

level indicator

Ratio”margin

is defined(OM)

as the is

ratio

of the

gross

proficommon

t to operating

expenses.

Most services transactions

operating

profit to sales, and

(91 percent)

also used

the CPM/TNMM

withItthewas

OMused

and operating

profiof

t tothe

operating

expensePLIs,

being such

the most

common PLIs (used

(PLI) used

to benchmark

results.

72 percent

time. Other

as the

67 percent

the time).

BerryofRatio

and mark up on total costs, made up the other 28 percent. As used here, “OM” is

defined as the ratio of operating profit to sales,12 and “Berry Ratio” is defined as the ratio of

Sources of Comparables, Comparables Selection

Criteria, and Nature of Adjustments to Comparables or Tested Party Data

gross profit to operating expenses.13 Most

services transactions (91 percent) also used the

§ 521(b)(2)(D)(v-vii)

CPM/TNMM with the OM and operating profit to operating expense being the most common

PLIs

(used

67 percent

of the

time).

For the

APAs

executed

in 2024 that

involved

the CPM/TNMM with a North American tested party, the most widely used data source

for comparables was Standard and Poor’s Compustat/Capital IQ database. Different sources were used in other cases (e.g., where the

tested11party was not a North American entity or where transaction-based methods were applied). Other commonly used databases are

thebelow.

executed APAs involve a tested party. Whether an APA involves a tested party would depend on the

listed inNot

the all

table

transfer pricing method used.

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

Table135: Sources of Comparable Data

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

Bureau van Dijk (BvD) Orbis

Capitaline

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.

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.

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).

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

April 7, 2025

1400

Bulletin No. 2025–15

Ranges and Adjustment Mechanisms

§ 521(b)(2)(D)(viii-ix)

Most transactions covered in 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 would 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 2024 were either a single year, the term of the APA only, or the term of the APA plus rollback years.

APAs executed in 2024 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 2024

§ 521(b)(2)(D)(x)

Table 6: Term Lengths of APAs Executed in 2024

Term Length (years)

Average

Number of APAs

As described in § 3.03(1) 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 2024, 28 percent included rollback years. A substantial number of

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

Bulletin No. 2025–15

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April 7, 2025

Amount

of TimeofTaken

Complete

and Renewal

Amount

TimetoTaken

to New

Complete

New APAs

and Renewal APAs

§ 521(b)(2)(E)

Table 7: Months to Complete New and Renewal APAs Executed in 2024

Unilateral &

Unilateral

Bilateral

Unilateral

Bilateral Unilateral & Bilateral

Bilateral

Average

Median

Average

Median

Average

Median

Average Median Average Median Average

Median

New

28.9

45.9

40.8

45.3

40.8

28.9

45.9

40.8

45.3

40.8

New

Renewal

24.3

29.3

36.0

30.8

34.5

30.8

24.3

29.3

36.0

30.8

34.5

30.8

Renewal

New & Renewal

25.0

29.3

40.5

34.8

39.1

33.5

25.0

29.3

40.5

34.8

39.1

33.5

New & Renewal

Months to Complete New and Renewal APAs Executed in 2024

Months to Complete

50.0

New

40.0

30.0

Renewal

20.0

New &

Renewal

10.0

0.0

Average

Median

Unilateral

Average

Median

Bilateral

Type of APA

Average

Median

Unilateral &

Bilateral

Median completion time continued to decrease in 2024 (33.5 months versus 42.0 months in

Median

completion time continued to decrease in 2024 (33.5 months versus 42.0 months in 2023).

2023).

Eﬀorts to Ensure Compliance with APAs

Efforts to Ensure Compliance with APAs

§ 521(b)(2)(F)

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

termsAs

anddescribed

conditions of

APAs. The

filing and

review

of thesetaxpayers

annual reports

critical parts

of the

APA process.

annual

intheir

§ 7.02(1)

of Rev.

Proc.

2015-41,

areare

required

to file

annual

reportsThrough

reportdemonstrate

review, the APMA

Program

monitors

taxpayer

compliance

with

APAs

contemporaneous

basis.

Annual

report

review

also

compliance with the terms and conditions of their APAs. The filing and review of

provides

current

information

the

success

problems

associated

with

the

various

TPMs

adopted

the

APA

process.

these annual reports are critical parts of the APA process. Through annual report review, the

APMA Program monitors taxpayer compliance with APAs on a contemporaneous basis. Annual

Nature of Documentation Required in Annual Report

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

§ 521(b)(2)(D)(xi)

various TPMs adopted in the APA process.

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

the APA’s

termsofand

conditions. Not every

annual report

will include

each of the items listed in Appendix C of the Model APA; items

Nature

Documentation

Required

in Annual

Report

are required

included

where

the

facts

demonstrate

need

for

such

documentation. The requirements for the information to be

§ 521(b)(2)(D)(xi)

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

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

Approaches for Sharing of Currency or Other Risks

and demonstrating compliance with the APA’s terms and conditions. Not every annual report

§ 521(b)(2)(D)(xii)

will include each of the items listed in Appendix C of the Model APA; items are required to be

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

April 7, 2025

1402

Bulletin No. 2025–15

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:

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

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

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

Operation.

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

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.

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. 2025–15

1403

April 7, 2025

{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.]

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.

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

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.

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.

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.

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.

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.

{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 7, 2025

1404

Bulletin No. 2025–15

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.

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.

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.

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.

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.”

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

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

Bulletin No. 2025–15

1405

April 7, 2025

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

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 7, 2025

Date: ___________________, 202___

1406

Bulletin No. 2025–15

APPENDIX A

COVERED ISSUES AND COVERED METHOD

Covered Issues.

[Define the Covered Issues.]

APA Term.

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

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. 2025–15

1407

April 7, 2025

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.]

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.

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)).]

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APPENDIX B

CRITICAL ASSUMPTIONS

This APA’s critical assumptions are:

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.]

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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:

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

A table of contents, organized as follows; and

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

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.

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.

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

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

effect.

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

incomplete.

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.

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

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.

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.

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

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.

{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.

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.

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.

A copy of the APA and any amendment.

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 7, 2025

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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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

Name

Title

Address

City/State/Zip

Phone/Fax

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. 2025–15

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.

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 7, 2025

Numerical Finding List1

Revenue Procedures:—Continued

2025-2, 2025-2 I.R.B. 305

2025-3, 2025-2 I.R.B. 306

2025-4, 2025-2 I.R.B. 306

2025-1, 2025-3 I.R.B. 431

2025-5, 2025-3 I.R.B. 433

2025-6, 2025-5 I.R.B. 526

2025-8, 2025-13 I.R.B. 1384

2025-13, 2025-15 I.R.B. 1392

2025-7, 2025-1 I.R.B. 301

2025-8, 2025-3 I.R.B. 427

2025-9, 2025-4 I.R.B. 491

2025-10, 2025-4 I.R.B. 492

2025-11, 2025-4 I.R.B. 501

2025-12, 2025-4 I.R.B. 512

2025-6, 2025-6 I.R.B. 713

2025-14, 2025-7 I.R.B. 770

2025-13, 2025-8 I.R.B. 816

2025-15, 2025-11 I.R.B. 1090

2025-16, 2025-11 I.R.B. 1100

2025-17, 2025-13 I.R.B. 1382

Notices:

Revenue Rulings:

2025-1, 2025-3 I.R.B. 415

2025-2, 2025-3 I.R.B. 418

2025-4, 2025-3 I.R.B. 419

2025-5, 2025-3 I.R.B. 426

2025-3, 2025-4 I.R.B. 488

2025-7, 2025-5 I.R.B. 524

2025-9, 2025-6 I.R.B. 681

2025-10, 2025-6 I.R.B. 682

2025-11, 2025-6 I.R.B. 704

2025-13, 2025-6 I.R.B. 710

2025-6, 2025-8 I.R.B. 799

2025-8, 2025-8 I.R.B. 800

2025-12, 2025-8 I.R.B. 813

2025-14, 2025-10 I.R.B. 980

2025-15, 2025-11 I.R.B. 1089

2025-16, 2025-13 I.R.B. 1378

2025-17, 2025-14 I.R.B. 1387

2025-1, 2025-3 I.R.B. 307

2025-2, 2025-3 I.R.B. 309

2025-3, 2025-4 I.R.B. 443

2025-4, 2025-7 I.R.B. 758

2025-5, 2025-7 I.R.B. 767

2025-6, 2025-11 I.R.B. 1064

2025-7, 2025-13 I.R.B. 1239

2025-8, 2025-15 I.R.B. 1390

Bulletin 2025–15

Announcements:

Proposed Regulations:

REG-117213-24, 2025-3 I.R.B. 433

REG-134420-10, 2025-4 I.R.B. 513

REG-105479-18, 2025-5 I.R.B. 527

REG-116610-20, 2025-5 I.R.B. 638

REG-115560-23, 2025-6 I.R.B. 716

REG-123525-23, 2025-6 I.R.B. 726

REG-124930-21, 2025-7 I.R.B. 772

REG‑100669‑24, 2025-8 I.R.B. 819

REG-101268-24, 2025-8 I.R.B. 836

REG-107420-24, 2025-8 I.R.B. 854

REG-116085-23, 2025-8 I.R.B. 865

REG-118988-22, 2025-8 I.R.B. 869

REG-107895-24, 2025-9 I.R.B. 972

REG-110878-24, 2025-9 I.R.B. 979

REG-112261-24, 2025-10 I.R.B. 983

Treasury Decisions:

10016, 2025-3 I.R.B. 313

10020, 2025-3 I.R.B. 408

10018, 2025-4 I.R.B. 446

10019, 2025-4 I.R.B. 482

10017, 2025-5 I.R.B. 517

10028, 2025-6 I.R.B. 660

10022, 2025-8 I.R.B. 773

10026, 2025-9 I.R.B. 878

10027, 2025-9 I.R.B. 897

10029, 2025-9 I.R.B. 936

10030, 2025-11 I.R.B. 1066

10024, 2025-12 I.R.B. 1104

10023, 2025-13 I.R.B. 1259

Revenue Procedures:

2025-1, 2025-1 I.R.B. 1

2025-2, 2025-1 I.R.B. 118

2025-3, 2025-1 I.R.B. 142

2025-4, 2025-1 I.R.B. 158

2025-5, 2025-1 I.R.B. 260

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin

2024–52, dated December 23, 2024.

April 7, 2025

Bulletin No. 2025–15

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–15

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin

2024–52, dated December 23, 2024.

Bulletin No. 2025–15

iii

April 7, 2025

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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