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Advance Pricing Agreements
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Book Synopsis Advance Pricing Agreements by : Michelle Markham
Download or read book Advance Pricing Agreements written by Michelle Markham and published by Kluwer Law International B.V.. This book was released on 2012-06-28 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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. This is the first book to offer expert insights on APAs from a practical perspective. By focusing on the United States and Australia, the two countries that were at the forefront of adopting APAs and whose wealth of experience over two decades confirms their APA programs as the global paradigms, the author is able to highlight the advantages and disadvantages of pursuing an APA and to shed light on the powerful efficacy of this strategy for avoiding transfer pricing disputes. In addition, the author enlists the views of revenue authorities, transfer pricing practitioners, and corporate counsel who deal with the realities of transfer pricing assessment and compliance on an ongoing basis, offering acute insight into how APAs really work in a practical way. This book contributes to the body of knowledge on APAs in the context of transfer pricing by providing in-depth scrutiny of the most important issues surrounding this critical area, and by examining innovations in APAs in the United States and in Australia. Its unmatched coverage will be welcomed by tax experts at law firms and multinational companies as well as by revenue officials, policymakers, and scholars and researchers in international taxation.
Download or read book Advance Pricing Agreements written by and published by . This book was released on 2014 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: QUESTIONS: 1. Are APAs available in your jurisdiction? Both unilateral and bilateral/multilateral? 2. Is there a special kind of APA for thin capitalization? 3. Is there a complexity/size threshold? 4. What is the legal basis for APAs? 5. Which part of the administration has authority to negotiate APAs? 6. What is the process for obtaining an APA? How long does this take? Is there a pre-filing phase? 7. What information must be provided? 8. What format and contents are specified for the APA itself? 9. For how long can APAs apply? 10. Will other affected tax authorities be informed? 11. What APA statistics are published?
Book Synopsis Advance Pricing Agreements - Looking for Transfer Pricing Certainty in Uncertain Times by : S.C. Wrappe
Download or read book Advance Pricing Agreements - Looking for Transfer Pricing Certainty in Uncertain Times written by S.C. Wrappe and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article discusses the advantages of an advanced pricing agreement (APA) for multinationals and recent changes in the U.S. APA process.
Book Synopsis Tax Administration by : United States. General Accounting Office
Download or read book Tax Administration written by United States. General Accounting Office and published by . This book was released on 2000 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Outlook for U.S. Advance Pricing Agreements by : S.C. Wrappe
Download or read book Outlook for U.S. Advance Pricing Agreements written by S.C. Wrappe and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors examine changes in the transfer pricing environment on both an international level and in the United States specifically, including changes in the IRS's approach to transfer pricing enforcement and in the advance pricing agreement (APA) process, to determine how these shifts affect taxpayers' desire to pursue an APA in the United States.
Book Synopsis Tax administration : IRS' advance pricing agreement program : report to the Honorable Byron L. Dorgan, U.S. Senate by :
Download or read book Tax administration : IRS' advance pricing agreement program : report to the Honorable Byron L. Dorgan, U.S. Senate written by and published by DIANE Publishing. This book was released on with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transfer Pricing by : Michael F. Patton
Download or read book Transfer Pricing written by Michael F. Patton and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Advance Pricing Agreements and COVID-19 by : S.F. Foley
Download or read book Advance Pricing Agreements and COVID-19 written by S.F. Foley and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors explain how recent changes to the U.S. advance pricing agreement (APA) model confirm the potential to amend existing APAs and highlight the value of the APA process to address extraordinary economic disruption through tailored long-term solutions.
Book Synopsis Advance Pricing Arrangement Series : Americas by : Matthew Frank
Download or read book Advance Pricing Arrangement Series : Americas written by Matthew Frank and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance pricing agreements keep getting more important. APAs save resources for both the participating companies and tax authorities. The authors show how the programs are working and growing in the Americas.
Book Synopsis Improving the Effectiveness of the International Advance Pricing Agreement Process by : Z. Mulachella
Download or read book Improving the Effectiveness of the International Advance Pricing Agreement Process written by Z. Mulachella and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines various factors of international advance pricing agreements (APAs) that are assessed from the perspective of the general standards of the programmes of five selected countries.
Book Synopsis Evolution of Advance Pricing Agreement Processes : Current and Future Experience in the United States by : M.P. Thomas
Download or read book Evolution of Advance Pricing Agreement Processes : Current and Future Experience in the United States written by M.P. Thomas and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The international tax world has never been more dynamic for both tax authorities and multinational enterprises alike, with rapid commercial and technological advances, increased transparency, fundamental changes to longstanding tax paradigms, and various (often bold) measures by governments to protect their tax bases. Transfer pricing will remain the principal international tax issue, and a familiar tool - advance pricing agreements - may be more important than ever.
Book Synopsis Transfer Pricing by : Ernst & Young International
Download or read book Transfer Pricing written by Ernst & Young International and published by . This book was released on 1995 with total page 30 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Advance Pricing Agreements:A Global Analysis: Is There a Safe Harbour for Multinational Enterprises Operating in a Global Economy? by : Jose Carrero
Download or read book Advance Pricing Agreements:A Global Analysis: Is There a Safe Harbour for Multinational Enterprises Operating in a Global Economy? written by Jose Carrero and published by Springer. This book was released on 1998-10-16 with total page 184 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tax Administration by : United States Accounting Office
Download or read book Tax Administration written by United States Accounting Office and published by Createspace Independent Publishing Platform. This book was released on 2018-02-13 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: GGD-00-168 Tax Administration: IRS' Advance Pricing Agreement Program
Book Synopsis Using Advance Pricing Agreements to Mitigate Transfer Pricing Risk by :
Download or read book Using Advance Pricing Agreements to Mitigate Transfer Pricing Risk written by and published by . This book was released on 2008 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Impact of the COVID-19 Pandemic on Advance Pricing Agreements by : B. Gibert
Download or read book The Impact of the COVID-19 Pandemic on Advance Pricing Agreements written by B. Gibert and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The COVID-19 pandemic may impact transfer pricing policies applied within multinational groups. As a result, one could legitimately wonder whether the pandemic could also impact advance pricing agreements (APAs) either concluded or under discussion between tax administrations and enterprises. This question is of foremost importance given that the terms and conditions of APAs are set to ensure tax certainty. In such circumstances, taxpayers could examine how potential changes triggered by the COVID-19 pandemic could impact APAs (section 1.) and what the procedural impact of the COVID-19 pandemic would be on APAs concluded or under discussion (section 2.).
Book Synopsis The Advance Pricing Agreement (APA) Program by :
Download or read book The Advance Pricing Agreement (APA) Program written by and published by . This book was released on 1993 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt:
