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The Advance Pricing Agreement Apa Program
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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.
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:
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 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:
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 A New Approach to the Venezuelan APA Program - Improvements Modeled after the US APA Program by : Andres E. Bazo
Download or read book A New Approach to the Venezuelan APA Program - Improvements Modeled after the US APA Program written by Andres E. Bazo and published by . This book was released on 2009 with total page 17 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper reviews the Advance Pricing Agreement (APA) Program in the United States, based on the Internal Revenue Code Revenue Procedure 2006-9 and Announcement 2008-27 and the differences with the APA Program in Venezuela, established in the Venezuelan Income Tax Law. Additionally, the paper proposes improvements to the Venezuelan APA Program modeled after the US APA Program as a way to provide a better service by the Tax Administration in Venezuela for taxpayers looking to obtain an Advance Pricing Agreement.
Book Synopsis U.S. APA Program Changes Positively Impact U.S.-Japan APAs by : S.C. Wrappe
Download or read book U.S. APA Program Changes Positively Impact U.S.-Japan APAs written by S.C. Wrappe and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines recent changes to the U.S. Advance Pricing Agreement (APA) Program and conclude that U.S.-Japan bilateral APAs are more desirable than ever for Japan-based multinational corporations.
Book Synopsis A Critical Analysis of the Viability of Advance Pricing Agreement Regime -The Indian Experience by : Asma Hussain
Download or read book A Critical Analysis of the Viability of Advance Pricing Agreement Regime -The Indian Experience written by Asma Hussain and published by . This book was released on 2020 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Government of India and the CBDT rolled out one of the most ambitious reforms in 2012 - the introduction of the Advance Pricing Agreement (APA) programme. The intention behind taking this step was to dismantle the idea of India as jurisdiction where the tax administration ran an aggressive transfer pricing regime. This reform was also aimed at providing certainty to MNEs in respect of their transfer pricing of international transactions, while providing them an incentive to invest in India. These ideas have slowly manifested themselves into reality. Hundreds of APAs have been signed in the last seven odd years, which in turn has extended comfort and certainty to MNEs. The complexity of the cases has been proportionally increasing with each passing year. In the year 2018-19 India has undertaken agreements such as, payment of royalty, transfer of intangibles, and Advertisement, Marketing and Promotion (AMP) expenses in respect of international transactions. Concomitantly, the adoption of transfer pricing mechanisms such as profit splitting and CUP became imperative. Ensuring that issues of such complex nature are resolved would bode well for the future of the Programme. Through this paper, the researcher aims to trace the inception, evolution, and the historical background of the Advance Pricing Agreement programme in India. The paper then goes on to look into the procedure and compliance requirements under APAs. The next part of the paper examines the different kinds of agreements, i.e., unilateral and bilateral agreements, and their features and differences. In the next section, the researcher attempts to analyze Indo-USA relations with respect to APAs. Lastly, the paper concludes by appreciating the present position of the APA regime in India, and by presenting some suggestions that would help achieve the objectives more effectively and efficiently for which APA was introduced.
Book Synopsis Transfer Pricing and Dispute Resolution by : Anuschka Bakker
Download or read book Transfer Pricing and Dispute Resolution written by Anuschka Bakker and published by IBFD. This book was released on 2011 with total page 807 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.
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 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 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 APA Programme Introduced in Ireland by : D. McSwiney
Download or read book APA Programme Introduced in Ireland written by D. McSwiney and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article provides an overview of Revenue's guidelines on the operation of a new formalised advance pricing agreement (APA) programme, which is effective from 1 July 2016. APAs are intended to minimise the likelihood of double taxation and prevent international tax disputes to complex intercompany transactions.
Book Synopsis Comments on 2006 Annual Report on Advance Pricing Agreement Programme by : S.N. Allen
Download or read book Comments on 2006 Annual Report on Advance Pricing Agreement Programme written by S.N. Allen and published by . This book was released on 2007 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article analyses the Annual Report, with a focus on changes over the years and possible future developments in the APA programme.
Download or read book Uniform Issue List written by and published by . This book was released on 1986 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Internal Revenue Bulletin by : United States. Internal Revenue Service
Download or read book Internal Revenue Bulletin written by United States. Internal Revenue Service and published by . This book was released on 2009 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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.
