Evolution of APA regime

The Resource Evolution of APA regime
Label
Evolution of APA regime
Creator
Subject
Language
eng
Summary
This book dedicated to the global advance pricing agreements or arrangements (APA) regime, furnishes a thorough, detailed discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. APAs, designed as a dispute prevention mechanism for transfer pricing related issues, impart certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has progressively taken hold worldwide and evolved along several facets with key characteristics. The analysis covers the following elements: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus before the grant of APAs and other relevant issues. An extended case study of India's APA programme also forms a part of this book and highlights a few of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction

Context

Context of Evolution of APA regime

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