Transfer pricing (the pricing of cross-border intra-firm transactions between related parties) is now the top international tax issue faced by multinational enterprises. In an international taxation environment characterized by rigorous enforcement of transfer pricing documentation, disclosure, and audit processes, a need has arisen for multinationals to be cognizant of the impact of their 'tax risk appetite' on their relationship with taxation authorities and to be aware of how best to manage their transfer pricing arrangements. The most promising development has been the growing commitment to Advance Pricing Agreements (APAs) - arrangements made prospectively between a multinational taxpayer and one or more revenue authorities, agreeing on an appropriate set of criteria for the determination of the transfer pricing of the covered transactions over a period of time.
" ... discusses the factors to consider in deciding whether to seek an advance pricing agreement (APA), and details the considerations to take into account and the steps to take at each stage of the APA process, including the pre-filing ...
Tax administration: IRS' advance pricing agreement program
Chapters by several authors on the 2001 Netherlands transfer pricing regime and the amended Netherlands advance pricing agreements and advance tax rulings practice.
Overview of background, history and procedural framework related to advance pricing agreement programmes in various countries.
This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South ...