U.S. Competent Authority statistics: reveal high level of double tax relief, but faster processing times, but jump in U.S.-initiated tp cases

Tax Insights ()

On March 15, 2013, the U.S. Competent Authority office released statistics on competent authority cases for calendar year 2012. The statistics cover the number of competent authority cases submitted, the number of cases closed, and the completion time for these cases. The statistics address double taxation cases (i.e., those arising from an audit adjustment in either the United States or a foreign country) and other competent authority cases, such as permanent establishment and limitation on benefits requests. Statistics regarding Advance Pricing Agreement (“APA”) matters will be covered in a separate report, the annual APA Report, to be issued by the Advance Pricing and Mutual Agreement (“APMA”) Program.