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The impact of the COVID-19 pandemic on Advance Pricing Agreements Bruno Gibert Electrónico

By: Gilbert, Bruno.
Material type: ArticleArticlePublisher: 2020Subject(s): PRECIOS DE TRANSFERENCIA | PANDEMIAS | CORONAVIRUS | ACUERDOS PREVIOS SOBRE PRECIOS DE TRANSFERENCIA In: International Transfer Pricing Journal v. 27, n. 5, 2020 Summary: The COVID-19 pandemic may impact transfer pricing policies applied within multinational groups. As a result, one could legitimately wonder whether the pandemic could also impact advance pricing agreements (APAs) either concluded or under discussion between tax administrations and enterprises. This question is of foremost importance given that the terms and conditions of APAs are set to ensure tax certainty. In such circumstances, taxpayers could examine how potential changes triggered by the COVID-19 pandemic could impact APAs (section 1.) and what the procedural impact of the COVID-19 pandemic would be on APAs concluded or under discussion (section 2.).
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Resumen.

The COVID-19 pandemic may impact transfer pricing policies applied within multinational groups. As a result, one could legitimately wonder whether the pandemic could also impact advance pricing agreements (APAs) either concluded or under discussion between tax administrations and enterprises. This question is of foremost importance given that the terms and conditions of APAs are set to ensure tax certainty. In such circumstances, taxpayers could examine how potential changes triggered by the COVID-19 pandemic could impact APAs (section 1.) and what the procedural impact of the COVID-19 pandemic would be on APAs concluded or under discussion (section 2.).

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