Advance Pricing Agreements: Past, Present and Future by Michelle Markham

By Michelle Markham

move pricing (the pricing of cross-border intra-firm transactions among similar events) is now the head overseas tax factor confronted by means of multinational businesses. In a world taxation atmosphere characterised by way of rigorous enforcement of move pricing documentation, disclosure, and audit strategies, a necessity has arisen for multinationals to be cognizant of the influence in their ‘tax danger urge for food’ on their courting with taxation specialists and to pay attention to how top to control their move pricing preparations. the main promising improvement has been the growing to be dedication to increase Pricing Agreements (APAs) – preparations made prospectively among a multinational taxpayer and a number of profit gurus, agreeing on a suitable set of standards for the decision of the move pricing of the lined transactions over a time period. this can be the 1st booklet to supply specialist insights on APAs from a pragmatic standpoint. through concentrating on the U.S. and Australia, the 2 international locations that have been on the leading edge of adopting APAs and whose wealth of expertise over twenty years confirms their APA courses because the international paradigms, the writer is ready to spotlight the benefits and downsides of pursuing an APA and to make clear the robust efficacy of this method for fending off move pricing disputes. additionally, the writer enlists the perspectives of profit professionals, move pricing practitioners, and company advice who care for the realities of move pricing evaluation and compliance on an ongoing foundation, providing acute perception into how APAs particularly paintings in a realistic means. This e-book contributes to the physique of information on APAs within the context of move pricing by way of delivering in-depth scrutiny of crucial concerns surrounding this serious region, and by means of studying recommendations in APAs within the usa and in Australia. Its unequalled assurance may be welcomed via tax specialists at legislation corporations and multinational businesses in addition to through profit officers, policymakers, and students and researchers in foreign taxation.

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