Since the Guidelines were published in their original version in 1995, a significant number of OECD member countries have acquired experience with APAs. Those countries which do have some experience seem to be satisfied so far, so that it can be expected that under the appropriate circumstances the experience with APAs will continue to expand. The success of APA programs will depend on the care taken in determining the proper degree of specificity for the arrangement based on critical assumptions, the proper administration of the program, and the presence of adequate safeguards to avoid the pitfalls described above, in addition to the flexibility and openness with which all parties approach the process.
TPG2017 Chapter IV paragraph 4.170
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Category: OECD Transfer Pricing Guidelines (2017) | Tag: Advance pricing arrangement (APA)
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- TPG2022 Chapter IV paragraph 4.171There are some continuing issues regarding the form and scope of APAs that require greater experience for full resolution and agreement among member countries, such as the question of unilateral APAs. The Committee on Fiscal Affairs intends to monitor carefully any expanded use of APAs and to promote greater consistency...
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- TPG2022 Chapter IV paragraph 4.170Since the Guidelines were published in their original version in 1995, a significant number of OECD member countries have acquired experience with APAs. Those countries which do have some experience seem to be satisfied so far, so that it can be expected that under the appropriate circumstances the experience with...