Between those countries that use APAs, greater uniformity in APA practices could be beneficial to both tax administrations and taxpayers. Accordingly, the tax administrations of such countries may wish to consider working agreements with the competent authorities for the undertaking of APAs. These agreements may set forth general guidelines and understandings for the reaching of mutual agreement in cases where a taxpayer has requested an APA involving transfer pricing issues.
TPG2017 Chapter IV paragraph 4.175
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Advance pricing arrangement (APA)
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