Commentary

B4.181 Advance pricing agreements — OECD guidelines

Business tax
Business tax | Commentary

B4.181 Advance pricing agreements — OECD guidelines

Business tax | Commentary

B4.181 Advance pricing agreements — OECD guidelines

The flow of goods across national borders and the subsequent transfer pricing issues that arise necessarily involve more than one tax authority. As such, disputes often arise between the taxpayer and the tax authority (or two or more tax authorities). This section provides a discussion of some of the methods available to all parties to resolve such conflicts including advance pricing agreements (APAs) (below and B4.182), mutual agreement procedures B4.183and the EU Arbitration Convention B4.184.

The OECD definition of an APA is as follows:

'An advance pricing agreement (APA) is an arrangement that determines, in

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