International - Advance Pricing Agreements ("APAs")
APAs allow complex transfer pricing issues to be resolved on a prospective basis. They can provide solutions to situations where there is considerable difficulty or doubt in determining the method by which the arms length principle should be applied. In such cases, even though the process of reaching an agreement can require significant resources, an APA may prove more efficient than the retrospective examination of major transfer pricing issues and may allow the business to predict tax liabilities with greater certainty.
Further information about APAs may be found in Statement of Practice 3/99. The address for further advice, for arranging an exploratory expression of interest meeting, and for making an application is:
Revenue Policy International
1 Parliament Street
London
SW1A 2BQ
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