Internal Revenue Bulletin 2025-15 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2025–15
April 7, 2025
HIGHLIGHTS
OF THIS ISSUE
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 Improve-
ment Act of 1999, which requires the Secretary of the Trea-
sury to report annually to the public concerning Advance Pric-
ing Agreements (APAs) and the Advance Pricing and Mutual
Agreement Program (APMA Program), formerly known as the
Advance Pricing Agreement Program (APA Program). This
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 long-
term 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.
Finding Lists begin on page ii.

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 offi-
cial 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 sub-
stantive 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 other-
wise indicated. Procedures relating solely to matters of inter-
nal 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 rul-
ings 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, disbar-
ment 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
purposes for April 2025 (the current
month). Table 1 contains the short-
term, mid-term, and long-term applica-
ble 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 fed-
eral 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. How-
ever, under section 42(b)(2), the appli-
cable percentage for non-federally sub-
sidized 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
AnnualSemiannualQuarterlyMonthly
Short-term
AFR4.16%4.12%4.10%4.09%
110% AFR4.58%4.53%4.50%4.49%
120% AFR5.00%4.94%4.91%4.89%
130% AFR5.43%5.36%5.32%5.30%
Mid-term
AFR4.21%4.17%4.15%4.13%
110% AFR 4.64%4.59%4.56%4.55%
120% AFR5.06%5.00%4.97%4.95%
130% AFR5.49%5.42%5.38%5.36%
150% AFR6.36%6.26%6.21%6.18%
175% AFR7.43%7.30%7.23%7.19%
Long-term
AFR4.61%4.56%4.53%4.52%
110% AFR5.08%5.02%4.99%4.97%
120% AFR5.54%5.47%5.43%5.41%
130% AFR6.02%5.93%5.89%5.86%
REV. RUL. 2025-8 TABLE 2
Adjusted AFR for April 2025
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR3.15%3.13%3.12%3.11%
Mid-term adjusted AFR3.20%3.17%3.16%3.15%
Long-term adjusted AFR3.49%3.46%3.45%3.44%
April 7, 2025 1390 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 month3.49%
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.)
3.67%
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 credit8.02%
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
5.00%

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.
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, mid-
term, 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 Below-
Market 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

April 7, 2025 1392 Bulletin No. 2025–15
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 statisti-
cal 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

Bulletin No. 2025–15 1393 April 7, 2025
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 Operations
1

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 man-
agers, 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. Rev-
enue 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.
1
In 2017, Transfer Pricing Operations became Treaty & Transfer Pricing Operations (“TTPO”).
2
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.

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)
Unilateral Bilateral MultilateralTotal
Filed 1991-1999
3
401
Filed 2000-20236922,143502,885
Filed in 2024211426169
Total Filed 1991-2024 3,455

3

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)

Unilateral Bilateral Multilateral Total
Filed 1991-1999
3
401
Filed 2000-2023 692 2,143 50 2,885
Filed in 2024 21 142 6 169
Total Filed 1991-2024

3,455

The charts above illustrate the number of complete applications filed per year and the percentage
of bilateral requests received in 2024 per foreign country. As of December 31, 2024, APMA had
also received 42 user fee filings that were not yet accompanied by a substantially complete APA
application, in addition to the 169 complete APA applications.

3
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.
0
50
100
150
200
250
2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
Applications Filed
2015-2024
Japan
32%
India
26%
Canada
10%
Bilateral APAs
Filed by Country 2024
All Other Countries
Netherlands
6%
3%
Korea
4%
Italy
4%
France
4%
Germany
5%
Mexico
6%
The charts above illustrate the number of complete applications fi led per year and the percentage of bilateral requests received in
2024 per foreign country. As of December 31, 2024, APMA had also received 42 user fee fi lings that were not yet accompanied by a
substantially complete APA application, in addition to the 169 complete APA applications.
3
The fi rst 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: Executed
4
and Pending APAs
§ 521(b)(2)(C)(ii-vi)
Unilateral Bilateral MultilateralTotal
Total Executed 1991-20237211,679242,424
Total Executed in 20241311910142
Total Executed 1991-20247341,798342,566
Total Pending as of 12/31/20245148524560
Renewals Executed in 2024
5
1165783
Renewals Pending
6
as of 12/31/2024412188267

4

Table 2: Executed
4
and Pending APAs
§ 521(b)(2)(C)(ii-vi)
Unilateral Bilateral Multilateral
Total
Total Executed 1991-2023 721 1,679 24 2,424
Total Executed in 2024 13 119 10 142
Total Executed 1991-2024 734 1,798 34 2,566

Total Pending as of 12/31/2024 51 485 24 560

Renewals Executed in 2024
5
11 65 7 83
Renewals Pending
6
as of 12/31/2024 41 218 8 267

India
29%
Japan
23%
Italy
11%
Canada
6%
Korea
5%
Mexico
5%
Germany
4%
Netherlands
4%
France
4%
Switzerland
3%
United Kingdom
3%
All Other Countries
3%
Bilateral APAs
Executed by Country 2024
In 2024, the percentage of APA renewals executed increased (58 percent of all APAs executed in
2024 versus 47 percent of all APAs 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.

4
“Executed APAs” refers to APAs that were finalized and includes both initial and renewal APAs.
5
The number of renewals executed is included in the total number of APAs executed during the year.
6
The number of renewals still pending as of year-end is also included in the total number of pending APAs.
APAs Executed
2015-2024
2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
0
20
40
60
80
100
120
140
160
In 2024, the percentage of APA renewals executed increased (58 percent of all APAs executed in 2024 versus 47 percent of all APAs
executed in 2023). The charts above illustrate trends in the number of APAs executed per year and the countries involved in the bilat-
eral APAs that were executed in 2024.
4
“Executed APAs” refers to APAs that were fi nalized and includes both initial and renewal APAs.
5
The number of renewals executed is included in the total number of APAs executed during the year.
6
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

5

As the top chart illustrates, the number of pending requests increased slightly relative to
December 31, 2023. As of December 31, 2024, half of the pending bilateral APA requests
involved either Japan or India.

Table 3: APAs Revoked or Cancelled and Applications Withdrawn
§ 521(b)(2)(C)(vii)

Unilateral Bilateral Multilateral Total
Revoked or Cancelled 1991-2000
7
1
Revoked or Cancelled 2001-2023 8 2 0 10
Revoked or Cancelled in 2024 0 0 0 0
Total Revoked or Cancelled 1991-2024

11

Withdrawn 1991-2000
8
49
Withdrawn 2001-2023 78 168 2 248
Withdrawn in 2024 2 15 0 17
Withdrawn 1991-2024 314

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.
8
See supra note 7.
Pending APAs
2015-2024
2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
0
100
200
300
400
500
600
Pending Bilateral APAs
by Country
All Other Countries
16%
Japan
Italy
28%
3%
United Kingdom
3%
Germany
4%
India
Korea
22%
5%
MexicoCanada
6%13%
As the top chart illustrates, the number of pending requests increased slightly relative to December 31, 2023. As of December 31,
2024, half of the pending bilateral APA requests involved either Japan or India.
Table 3: APAs Revoked or Cancelled and Applications Withdrawn
§ 521(b)(2)(C)(vii)
Unilateral Bilateral MultilateralTotal
Revoked or Cancelled 1991-2000
7
1
Revoked or Cancelled 2001-202382010
Revoked or Cancelled in 20240000
Total Revoked or Cancelled 1991-2024
11
Withdrawn 1991-2000
8
49
Withdrawn 2001-2023781682248
Withdrawn in 2024215017
Withdrawn 1991-2024
314
7
The fi rst 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.
8
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)
Industry
Manufacturing 42
Wholesale/Retail Trade39
Services29
Management15
Finance, Insurance and Real Estate12
All Other Industries5

6

Table 4: APAs Executed in 2024 by Industry
§ 521(b)(2)(C)(viii)
Industry

Manufacturing 42
Wholesale/Retail Trade 39
Services 29
Management 15
Finance, Insurance and Real Estate 12
All Other Industries 5

Manufacturing
30%
Wholesale/Retail
Trade
27%
Services
20%
Management
11%
Finance, Insurance and Real Estate
8%
All Other Industries
4%
APAs Executed
in 2024 by Industry
Tab
le 4a: Manufacturing APAs Executed in 2024
Type of Manufacturing

Transportation Equipment 13
Computer and Electronic Product 10
Chemical 7
Miscellaneous
9
7
All Other Manufacturing 5

9
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.
Transportation
Equipment
32%
Computer and Electronic
Product
24%
Chemical
16%
Miscellaneous
16%
All Other
Manufacturing
12%
Type of Manufacturing APAs
Executed in 2024
Table 4a: Manufacturing APAs Executed in 2024
Type of Manufacturing
Transportation Equipment13
Computer and Electronic Product10
Chemical7
Miscellaneous
9
7
All Other Manufacturing5

6

Table 4: APAs Executed in 2024 by Industry
§ 521(b)(2)(C)(viii)
Industry

Manufacturing 42
Wholesale/Retail Trade 39
Services 29
Management 15
Finance, Insurance and Real Estate 12
All Other Industries 5

Table 4a: Manufacturing APAs Executed in 2024
Type of Manufacturing

Transportation Equipment 13
Computer and Electronic Product 10
Chemical 7
Miscellaneous
9
7
All Other Manufacturing 5

Transportation
Equipment
32%
Computer and Electronic
Product
24%
Chemical
16%
Miscellaneous
16%
All Other
Manufacturing
12%
Type of Manufacturing APAs
Executed in 2024

9
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.
Manufacturing
30%
Wholesale/Retail
Trade
27%
Services
20%
Management
11%
Finance, Insurance and Real Estate
8%
All Other Industries
4%
APAs Executed
in 2024 by Industry
9
Industries in the Miscellaneous Manufacturing subsector (NAICS Code 339) make a wide range of products that cannot readily be classifi ed in specifi c 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 Goods21
Merchant Wholesalers, Nondurable Goods
9
Clothing and Clothing Accessories Stores
4
All Other Wholesalers
5

7

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

Merchant Wholesalers, Durable Goods 21
Merchant Wholesalers, Nondurable Goods 9
Clothing and Clothing Accessories Stores 4
All Other Wholesalers 5

Merchant
Wholesalers, Durable
Goods
54%
Merchant
Wholesalers,
Nondurable Goods
23%
Clothing and
Clothing Accessories
Stores
10%
All Other
Wholesalers
13%
Type of Wholesale/Retail Trade APAs
Executed in 2024

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)]
Nature of the Relationships
§ 521(b)(2)(D)(i)

8

Part III. General Descriptions of APAs Executed in 2024
[Pub. L. 106-170 § 521(b)(2)(D) and (E)]

Nature of the Relationships
§ 521(b)(2)(D)(i)

Non-U.S. Parent &
U.S. Subsidiary
56%
U.S. Parent &
Non-U.S.
Subsidiary
37%
Sister Companies
6%
All Other Relationships
1%
Relationships between
Controlled Parties

As in prior years, more than half of the APAs executed in 2024 involved transactions between
non-U.S. parents and U.S. subsidiaries.

Covered Transactions, Functions and Risks, and Tested Parties
§ 521(b)(2)(D)(ii-iii)

Most of the transactions
10
covered in APAs executed in 2024 involve the sale of tangible goods
or the provision of services. Twenty-two percent of the transactions involve the use of intangible
property, which can be among the most challenging transactions in APMA’s inventory.

In the majority of APAs, the covered transactions involve numerous business functions and risks.
For instance, with respect to functions, APAs involving manufactured products typically involve

10
APAs often cover more than one type of transaction.
Sale of Tangible
Property into the U.S.
22%
Sale of Tangible
Property from the
U.S.
11%
Use of Intangible Property
by a U.S. Entity
16%
Use of Intangible Property by
a Non-U.S. Entity
6%
Provision of Services
by a U.S. Entity
18%
Provision of Services by a
Non-U.S. Entity
25%
All Other Types of
Transactions
2%
Types of Covered Transactions
As in prior years, more than half of the APAs executed in 2024 involved transactions between non-U.S. parents and U.S. subsidiaries.
Covered Transactions, Functions and Risks, and Tested Parties
§ 521(b)(2)(D)(ii-iii)

8

Part III. General Descriptions of APAs Executed in 2024
[Pub. L. 106-170 § 521(b)(2)(D) and (E)]

Nature of the Relationships
§ 521(b)(2)(D)(i)

As in prior years, more than half of the APAs executed in 2024 involved transactions between
non-U.S. parents and U.S. subsidiaries.

Covered Transactions, Functions and Risks, and Tested Parties
§ 521(b)(2)(D)(ii-iii)

Sale of Tangible
Property into the U.S.
22%
Sale of Tangible
Property from the
U.S.
11%
Use of Intangible Property
by a U.S. Entity
16%
Use of Intangible Property by
a Non-U.S. Entity
6%
Provision of Services
by a U.S. Entity
18%
Provision of Services by a
Non-U.S. Entity
25%
All Other Types of
Transactions
2%
Types of Covered Transactions
Most of the transactions
10
covered in APAs executed in 2024 involve the sale of tangible goods
or the provision of services. Twenty-two percent of the transactions involve the use of intangible
property, which can be among the most challenging transactions in APMA’s inventory.

In the majority of APAs, the covered transactions involve numerous business functions and risks.
For instance, with respect to functions, APAs involving manufactured products typically involve

10
APAs often cover more than one type of transaction.
Non-U.S. Parent &
U.S. Subsidiary
56%
U.S. Parent &
Non-U.S.
Subsidiary
37%
Sister Companies
6%
All Other Relationships
1%
Relationships between
Controlled Parties
Most of the transactions
10
covered in APAs executed in 2024 involve the sale of tangible goods or the provision of services. Twen-
ty-two percent of the transactions involve the use of intangible property, which can be among the most challenging transactions in
APMA’s inventory.
In the majority of APAs, the covered transactions involve numerous business functions and risks. For instance, with respect to func-
tions, 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
functions such as legal, fi nance, and human resources. Regarding risks, the controlled group may assume a variety of risks, including
market risks, R&D risks, fi nancial risks, credit and collection risks, product liability risks, and general business risks. In the APA
evaluation process, a signifi cant amount of time and eff ort 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.

10
APAs often cover more than one type of transaction.
Bulletin No. 2025–15 1399 April 7, 2025

9

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 functions such as legal, finance, and human resources. Regarding risks, the controlled
group may assume a variety of risks, including market risks, R&D risks, financial risks, credit
and collection risks, product liability risks, and general business risks. In the APA evaluation
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.

U.S. Distributor
39%
Non-U.S. Distributor
8%
U.S. Service Provider
8%
Non-U.S. Service
Provider
31%
U.S. Manufacturer
12%
All Other Types of
Tested Parties
2%
Types of Tested Parties

Consistent with prior years, U.S. distributors, U.S. manufacturers, and U.S. service providers
combined, comprised a majority of tested parties
11
in 2024, i.e., 59 percent.

Transfer Pricing Methods Used
§ 521(b)(2)(D)(iv)

In 2024, the most commonly used transfer pricing method (TPM) for both the sale of tangible
property and the use of intangible property continued to be the comparable profits
method/transactional net 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 PLIs, such as the
Berry Ratio 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
gross profit to operating expenses.
13
Most services transactions (91 percent) also used the
CPM/TNMM with the OM and operating profit to operating expense being the most common
PLIs (used 67 percent of the time).

11
Not all the executed APAs involve a tested party. Whether an APA involves a tested party would depend on the
transfer pricing method used.
12
See Treas. Reg. § 1.482-5(b)(4)(ii)(A).
13
See Treas. Reg. § 1.482-5(b)(4)(ii)(B).
Consistent with prior years, U.S. distributors, U.S. manufacturers, and U.S. service providers combined, comprised a majority of
tested parties
11
in 2024, i.e., 59 percent.
Transfer Pricing Methods Used
§ 521(b)(2)(D)(iv)
In 2024, the most commonly used transfer pricing method (TPM) for both the sale of tangible property and the use of intangible
property continued to be the comparable profi ts method/transactional net 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 mar-
gin (OM) is still the most common profi t level indicator (PLI) used to benchmark results. It was used 72 percent of the time. Other
PLIs, such as the Berry Ratio and mark up on total costs, made up the other 28 percent. As used here, “OM” is defi ned as the ratio of
operating profi t to sales,
12
and “Berry Ratio” is defi ned as the ratio of gross profi t to operating expenses.
13
Most services transactions
(91 percent) also used the CPM/TNMM with the OM and operating profi t to operating expense being the most common PLIs (used
67 percent of the time).
Sour ces of Comparables, Comparables Selection Criteria, and Nature of Adjustments to Comparables or Tested Party Data
§ 521(b)(2)(D)(v-vii)
For t he 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. Diff erent sources were used in other cases (e.g., where the
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
Bureau van Dijk (BvD) OrbisCapitaline TP
Global VantageRoyaltySource
ktMINERoyaltyStat
Ace TP
In making comparability adjustments as identifi ed in Treas. Reg. §§ 1.482-1(d)(2) and 1.482-5(c)(2)(iv), typical balance sheet adjust-
ments were made in most cases, including, where appropriate, adjustments for payables, receivables, inventory, and fi xed assets.
In addition, where appropriate, adjustments for diff erent accounting practices were made to convert from LIFO to FIFO inventory
accounting, and a small number of cases involved the accounting reclassifi cation of expenses, e.g., from COGS to operating expenses.
11
Not all the executed APAs involve a tested party. Whether an APA involves a tested party would depend on the transfer pricing method used.
12
See Treas. Reg. § 1.482-5(b)(4)(ii)(A).
13
See Treas. Reg. § 1.482-5(b)(4)(ii)(B).
April 7, 2025 1400 Bulletin No. 2025–15

Bulletin No. 2025–15 1401 April 7, 2025
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)Number of APAs
11
22
33
410
556
633
724
87
92
112
121
151
Average6
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.

Amount of Time Taken to Complete New and Renewal APAs
§ 521(b)(2)(E)
Table 7: Months to Complete New and Renewal APAs Executed in 2024

Unilateral Bilateral Unilateral & Bilateral
AverageMedianAverageMedianAverageMedian
New 28.928.945.940.845.340.8
Renewal 24.329.336.030.834.530.8
New & Renewal25.029.340.534.839.133.5

12

Amount of Time Taken to Complete New and Renewal APAs
§ 521(b)(2)(E)

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

Unilateral Bilateral
Unilateral &
Bilateral
Average Median Average Median
Average Median
New
28.9 28.9 45.9 40.8
45.3 40.8
Renewal
24.3 29.3 36.0 30.8
34.5 30.8
New & Renewal
25.0 29.3 40.5 34.8 39.1 33.5

Months to Complete New and Renewal APAs Executed in 2024

0.0
10.0
20.0
30.0
40.0
50.0
AverageMedianAverageMedianAverageMedian
UnilateralBilateralUnilateral &
Bilateral
Months to Complete
Type of APA
New
Renewal
New &
Renewal
Medi
an completion time continued to decrease in 2024 (33.5 months versus 42.0 months in
2023).

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 terms and conditions of their APAs. The filing and review of
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
report review also provides current information on the success or problems associated with the
various TPMs adopted in the APA process.

Nature of Documentation Required in Annual Report
§ 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
Median completion time continued to decrease in 2024 (33.5 months versus 42.0 months in 2023).
Eff orts to Ensure Compliance with APAs
§ 521(b)(2)(F)
As described in § 7.02(1) of Rev. Proc. 2015-41, taxpayers are required to fi le annual reports to demonstrate compliance with the
terms and conditions of their APAs. The fi ling and review of 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 report review also
provides current information on the success or problems associated with the various TPMs adopted in the APA process.
Nature of Documentation Required in Annual Report
§ 521(b)(2)(D)(xi)
APAs require taxpayers to fi le 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 specifi c 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 specifi c approaches for dealing with risks, including currency risk, such as adjustment mech-
anisms and/or critical assumptions.
April 7, 2025 1402 Bulletin No. 2025–15

Bulletin No. 2025–15 1403 April 7, 2025
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.
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.
5. 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).

April 7, 2025 1404 Bulletin No. 2025–15
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 Cov-
ered 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 Cov-
ered 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.
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 con-
stitutes 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.
6. 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.

Bulletin No. 2025–15 1405 April 7, 2025
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 author-
ity 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-li-
censed 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 Tax-
payer 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.

ii. Transmit any potentially sensitive information, including personally identifiable information, only via encrypted, pass-
word-protected attachments.
The User Guide at Sign and Send Documents Electronically | Internal Revenue Service (irs.gov) contains additional informati
about encrypting files and sending documents to IRS by email.
on
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: ___________________________ Date: ___________________, 202___
Jane Doe
Sr. Vice President (Taxes)
IRS
By: ___________________________ Date: ___________________, 202___
John M. Wall
Acting Director, APMA Program
April 7, 2025 1406 Bulletin No. 2025–15

Bulletin No. 2025–15 1407 April 7, 2025
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 fol-
lows: 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 rev-
enue (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

April 7, 2025 1408 Bulletin No. 2025–15
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 Mar-
gin 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 Proce-
dure 2015-41, section 7.01(1)), a conforming adjustment will be required as specified in Revenue Procedure 2015-41, sec-
tion 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, includ-
ing, 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)).]

Bulletin No. 2025–15 1409 April 7, 2025
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 clas-
sifications [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.]

April 7, 2025 1410 Bulletin No. 2025–15
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, con-
tractual terms, economic conditions, property, services, and assets employed) during the APA Year from the business oper-
ations 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 iden-
tify 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;

Bulletin No. 2025–15 1411 April 7, 2025
B. a description of any amounts paid or deemed paid (including amounts paid in satisfaction of such accounts pay-
able), 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 consolidat-
ing 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).

April 7, 2025 1412 Bulletin No. 2025–15
APPENDIX D
DEFINITIONS
The following definitions control for all purposes of this APA. The definitions appear alphabetically below:
TermDefinition
Annual ReportAn APA annual report within the meaning of Revenue Procedure 2015-41, sections 1.04 and
7.02.
A PAThis Advance Pricing Agreement, which is an “advance pricing agreement” within the
meaning of Revenue Procedure 2015-41, section 1.04.
APA RecordsThe records specified in Revenue Procedure 2015-41, section 7.04 and Appendix C of this
APA.
APA RequestTaxpayer’s request for this APA dated _________, including any amendments or
supplemental or additional information thereto.
APA YearThis term is defined in Appendix A of this APA.
Applicable generally accepted
accounting standards
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.
Covered Issue(s)This term is defined in Appendix A of this APA.
Covered Method(s)Transfer Pricing Method described in Appendix A of this APA.
Financial StatementsAs 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.
Foreign GroupWorldwide Group members that are not U.S. persons.
Foreign Participants[name the foreign entities involved in Covered Issues].
I.R.C.The Internal Revenue Code of 1986, 26 U.S.C., as amended.
Pub. L. 106-170The Ticket to Work and Work Incentives Improvement Act of 1999.
Revenue Procedure 2015-41Rev. Proc. 2015-41, 2015-35 IRB 263.
Transfer Pricing Method (TPM)A transfer pricing method within the meaning of Treasury Regulations section 1.482-1(b).
U.S. GAAPU.S. generally accepted accounting principles.
U.S. GroupWorldwide Group members that are U.S. persons.
U.S. ReturnFor 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.}
Worldwide GroupTaxpayer 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.

Bulletin No. 2025–15 1413 April 7, 2025
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 infor-
mation 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.

April 7, 2025 1414 Bulletin No. 2025–15
Internal Revenue ServiceAPMA Case No.
Large Business and International DivisionReviewer
Treaty & Transfer Pricing OperationsTeam Leader
Advance Pricing Mutual Agreement ProgramEconomist
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 PersonName
Title
If necessary, include a Address
current Form 2848 for theCity/State/Zip
Notice PersonPhone/Fax
Email
Current Representative, if anyName
Title
Include a current Form 2848Address
for the representativeCity/State/Zip
Phone/Fax
Email
Date Annual Report Filed (to be filled in by APMA):

Bulletin No. 2025–15 i April 7, 2025
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 pub-
lished 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 confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished 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 pub-
lished ruling that is not considered deter-
minative 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 sub-
stance 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 rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings 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.
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 ii Bulletin No. 2025–15
Numerical Finding List
1
Bulletin 2025–15
Announcements:
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
Notices:
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
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
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
Revenue Procedures:—Continued
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
Revenue Rulings:
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
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
1
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
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2025–15
1
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.

Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300
INTERNAL REVENUE BULLETIN
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