Share with your friends

KPMG report: New tool for APA submissions

KPMG report: New tool for APA submissions

Taxpayers making advance pricing agreement (APA) submissions may be asked to use the new “functional cost diagnostic model"—a taxpayer information data analytics tool.


Related content

The IRS’s Advance Pricing and Mutual Agreement Program (APMA) released instructions (in a memo) that explain how the functional cost diagnostic model will be used to better understand “...the respective contributions each controlled taxpayer makes to exercise control over the economically significant risks surrounding proposed covered transactions.” Read TaxNewsFlash

Nevertheless, the functional cost diagnostic memo leaves many questions unanswered. 

Read an April 2019 report [PDF 82 KB] prepared by KPMG LLP: What's News in Tax: FCD Model: A New Tool for APA Submissions

© 2021 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal

Stay up to date with what matters to you

Gain access to personalized content based on your interests by signing up today

Sign up today