USA Law and Practice Contributed by: Kevin Spencer, Kim Marie Boylan, Nicholas Wilkins and Christina Culver, White & Case LLP
16. Transparency and Confidentiality 16.1 Publication of Information on APAs or Transfer Pricing Audit Outcomes Statistical information on APAs is published annually. The information includes the number of executed and pending APAs, as well as the number of APAs by juris - diction, industry, controlled party relationship, type of transaction, method used and similar metrics. 16.2 Use of “Secret Comparables” Secret comparables are not used.
15.2 Restrictions on Outbound Payments Relating to Controlled Transactions The USA does not restrict outbound payments relating to controlled transactions. 15.3 Effects of Other Countries’ Legal Restrictions There are detailed regulations addressing when oth - er countries’ legal restrictions will be respected in determining transfer pricing allocations. The validity of these regulations is currently being challenged in court.
300 CHAMBERS.COM
Powered by FlippingBook