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

By Michelle Markham

move pricing (the pricing of cross-border intra-firm transactions among similar events) is now the pinnacle overseas tax factor confronted by way of multinational businesses. In a global taxation setting 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 probability urge for food’ on their dating with taxation specialists and to concentrate on how top to regulate their move pricing preparations. the main promising improvement has been the turning out 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 choice of the move pricing of the coated transactions over a time period. this can be the 1st booklet to provide specialist insights on APAs from a pragmatic point of view. via targeting the USA and Australia, the 2 nations that have been on the leading edge of adopting APAs and whose wealth of expertise over twenty years confirms their APA courses because the worldwide paradigms, the writer is ready to spotlight the benefits and drawbacks of pursuing an APA and to make clear the strong efficacy of this process for averting move pricing disputes. furthermore, the writer enlists the perspectives of profit gurus, move pricing practitioners, and company suggestions who care for the realities of move pricing overview and compliance on an ongoing foundation, delivering acute perception into how APAs fairly paintings in a pragmatic approach. This ebook contributes to the physique of information on APAs within the context of move pricing by means of delivering in-depth scrutiny of an important concerns surrounding this serious region, and by means of analyzing options in APAs within the usa and in Australia. Its unrivaled insurance may be welcomed by means of tax specialists at legislations companies and multinational businesses in addition to via profit officers, policymakers, and students and researchers in overseas taxation.

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

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