Tuesday, July 16, 2013

Transfer Pricing - APA


  • An Advance Pricing Agreement (APA) is a pact between a taxpayer and a tax authority on pricing of future inter-company transactions.
  • APA provides certainty on pricing and the methodology for inter-company transactions and also eliminates double taxation risks
  • The parties to an APA agree on the transfer pricing methodology to be applied to such transactions for a future period of time
  • In India, besides unilateral APA between the tax authority and a taxpayer, bilateral and multilateral APAs involving the tax authorities of other countries are also permitted

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