Advance Pricing Agreements: Past, Present and Future - download pdf or read online

By Michelle Markham

ISBN-10: 9041140425

ISBN-13: 9789041140425

move pricing (the pricing of cross-border intra-firm transactions among comparable events) is now the head foreign tax factor confronted through multinational organizations. In a global taxation surroundings characterised by means of rigorous enforcement of move pricing documentation, disclosure, and audit tactics, a necessity has arisen for multinationals to be cognizant of the influence in their ‘tax threat urge for food’ on their dating with taxation gurus and to pay attention to how most sensible to control their move pricing preparations. the main promising improvement has been the becoming dedication to increase Pricing Agreements (APAs) – preparations made prospectively among a multinational taxpayer and a number of profit specialists, agreeing on a suitable set of standards for the selection of the move pricing of the lined transactions over a time period. this can be the 1st ebook to supply professional insights on APAs from a realistic standpoint. through concentrating on the us and Australia, the 2 international locations that have been on the leading edge of adopting APAs and whose wealth of expertise over 20 years confirms their APA courses because the worldwide paradigms, the writer is ready to spotlight the benefits and downsides of pursuing an APA and to make clear the robust efficacy of this technique for fending off move pricing disputes. furthermore, the writer enlists the perspectives of profit professionals, move pricing practitioners, and company assistance who care for the realities of move pricing overview and compliance on an ongoing foundation, providing acute perception into how APAs fairly paintings in a pragmatic approach. This ebook contributes to the physique of data on APAs within the context of move pricing via delivering in-depth scrutiny of crucial concerns surrounding this severe zone, and through reading options in APAs within the usa and in Australia. Its unrivaled insurance may be welcomed by way of tax specialists at legislation businesses and multinational businesses in addition to through profit officers, policymakers, and students and researchers in foreign taxation.

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


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