Advance pricing agreements: a step forward in transfer pricing dispute resolution? : a story from developing countries Maria R.U.D. Tambunan, Haula Rosdiana and Edi Slament Irianto
By: Tambunan, Maria R.U.D
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Contributor(s): Rosdiana, Haula | Irianto, Edi Slamet.
Material type: 
ArticlePublisher: 2020Subject(s): PRECIOS DE TRANSFERENCIA | ACUERDOS PREVIOS SOBRE PRECIOS DE TRANSFERENCIA | PAISES EN DESARROLLOOnline resources: Click here to access online
In:
Journal of Taxation of Investments v. 37, n. 4, Summer 2020, p. 35-59Summary: The study discusses advance pricing agreement (APA) implementation in several developing countries as a measure to reduce transfer pricing disputes. For developing countries, the issue of transfer pricing is critical and has not concerned merely an administrative obligation to document the price determination.
The cost of transfer pricing audits through the settlement stage is quite high due to specifi c challenges such as lack of proper comparable data and lack of expertise on transfer pricing. Based on the review of APA implementation in several developing countries, the implementation has been relatively successful in reducing transfer pricing litigation. The number of APA applications has increased, specifi cally when each country has committed to adopt BEPS Action 14 into its domestic law. Furthermore, each tax administration has taken steps to promote APAs, considering that this way to comply with tax obligations is more effi cient than engaging in drawn-out disputes with taxpayers.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 235/2020/4-2 (Browse shelf) | Available | OP 235/2020/4-2 |
Disponible también en formato electrónico.
Resumen.
The study discusses advance pricing agreement (APA) implementation in several developing countries as a measure to reduce transfer pricing disputes. For developing countries, the issue of transfer pricing is critical and has not concerned merely an administrative obligation to document the price determination.
The cost of transfer pricing audits through the settlement stage is quite high due to specifi c challenges such as lack of proper comparable data and lack of expertise on transfer pricing. Based on the review of APA implementation in several developing countries, the implementation has been relatively successful in reducing transfer pricing litigation. The number of APA applications has increased, specifi cally when each country has committed to adopt BEPS Action 14 into its domestic law. Furthermore, each tax administration has taken steps to promote APAs, considering that this way to comply with tax obligations is more effi cient than engaging in drawn-out disputes with taxpayers.
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