Advance Pricing Agreements:A Global Analysis: Is There a Safe Harbour for Multinational Enterprises Operating in a Global Economy?
Publisher: Springer; 1 edition (October 16, 1998)
Format: PDF / Kindle / ePub
Size: 7 MB
Downloadable formats: PDF
Is there a safe harbour for multinational enterprises operating in a global economy? This book assesses whether Advance Pricing Agreements (APAs) constitute a suitable solution to the major problems and controversies in the area of transfer pricing. The 1980s brought increased confrontation between taxpayers and tax administrators and between jurisdictions implementing and enforcing diverging transfer pricing legislation. The author analyses the legal characteristics of APAs; practical problems regarding their implementation; and the benefits, drawbacks, and alternatives confronted by the parties to such agreements. This study is in large measure based on the U.S. procedures on APAs which make up the most advanced regulation in this field. In addition, the work describes the worldwide practice on APAs, the OECD guidelines, and the APA procedures of other jurisdictions which basically follow U.S. legislation. Its informativeness and extent of coverage make this work essential reading for practitioners, in-house counsel, and academics active in the area of international taxation.