Page:United States Statutes at Large Volume 113 Part 3.djvu/408

 113 STAT. 1926 PUBLIC LAW 106-170—DEC. 17, 1999 (ii) advance pricing agreements executed cumulatively to date and during such calendar year; (iii) renewals of advance pricing agreements issued; (iv) pending requests for advance pricing agreements; (v) pending renewals of advance pricing agreements; (vi) for each of the items in clauses (ii) through (v), the number that are unilateral, bilateral, and multilateral, respectively; (vii) advance pricing agreements revoked or canceled, and the number of withdrawals from the advance pricing agreement program; and (viii) advance pricing agreements finalized or renewed by industry. (D) General descriptions of— (i) the nature of the relationships between the related organizations, trades, or businesses covered by advance pricing agreements; (ii) the covered transactions and the business functions performed and risks assumed by such organizations, trades, or businesses; (iii) the related organizations, trades, or businesses whose prices or results are tested to determine compliance with transfer pricing methodologies prescribed in advance pricing agreements; (iv) methodologies used to evaluate tested parties and transactions and the circumstances leading to the use of those methodologies; (v) critical assumptions made and sources of comparables used; (vi) comparable selection criteria and the rationale used in determining such criteria; (vii) the nature of adjustments to comparables or tested parties; (viii) the nature of any ranges agreed to, including information regarding when no range was used and why, when interquartile ranges were used, and when there was a statistical narrowing of the comparables; (ix) adjustment mechanisms provided to rectify results that fall outside of the agreed upon advance pricing agreement range; (x) the various term lengths for advance pricing agreements, including rollback years, and the number of advance pricing agreements with each such term length; (xi) the nature of documentation required; and (xii) approaches for sharing of currency or other risks. (E) Statistics regarding the amount of time taken to complete new and renewal advance pricing agreements. (F) A detailed description of the Secretary of the Treasury's efforts to ensure compliance with existing advance pricing agreements. (3) CONFIDENTIALITY.—The reports required by this subsection shall be treated as authorized by the Internal Revenue

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