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- Title
Advance Pricing Agreements - A Strategic Tool in Global Transfer Pricing Management.
- Authors
Canale, David J.; Wrappe, Steven C.
- Abstract
The article focuses on the Advance Pricing Agreements (APA) program of the U.S. Internal Revenue Service (IRS). The program was created in March 1991 to prevent transfer pricing contentions by drafting a concession with taxpayers. The benefits of APA is the assurance of tax treatments including independence from U.S. penalty, adjustments and double tax. The five phases of the APA process are also discussed such as preparation, administration and renewal. Its objectives, strategies and user fees are presented. The function of the IRS employees is defined.
- Subjects
UNITED States; TAXATION; TRANSFER pricing; ADVANCE pricing agreements; INTERNATIONAL business enterprises; UNITED States. Internal Revenue Service
- Publication
Tax Executive, 2008, Vol 60, Issue 3, p193
- ISSN
0040-0025
- Publication type
Article