Validity Of Advance Pricing Agreement

Gepostet von am Okt 13, 2021 in Allgemein | Keine Kommentare

If the transactions covered by the original agreement are evaluated, the extension of the APA may be a faster and simpler procedure than the processing of the initial APP application. Advance rulings from the Finnish tax administration or the tax centre do not eliminate the risk of international double taxation. The question of how a party close to the transaction is treated when taxing the other party is always left open in these decisions. On the other hand, the process of negotiating an ABS between two or more states can be lengthy and will not necessarily result in an agreement. The negotiations on the JPA require substantial contributions from taxpayers and competent authorities. Therefore, the ABS procedure is particularly appropriate for situations where the parties need to agree on key transfer pricing issues, which are free to interpret. . . .