Advance pricing agreement Archives - Kluwer International Tax Blog

Advance pricing agreement, Australia, OECD

An evaluation of Australia’s Advance Pricing Arrangement program in light of the OECD’s Bilateral Advance Pricing Arrangement Manual

Simrata Nand/March 7, 2023March 6, 2023 /Leave a comment

On 28 September 2022, the Organisation for Economic Cooperation and Development (OECD) published its Bilateral Advance Pricing Arrangement Manual (BAPAM).[1] The BAPAM aims to help streamline bilateral advance pricing arrangement (BAPA) programs by providing 29 best practice recommendations to resolve commonly experienced issues.[2] Advance pricing arrangements (APAs) are a prospective dispute resolution mechanism for cross-border…

Advance pricing agreement, Transfer Pricing

Heads I Win, Tails You Lose. Or is an APA a contract subject to contract law?

William Byrnes (Texas A&M University Law)/August 29, 2022 /1 Comment

On August 25, 2022, the Sixth Circuit Court of Appeals answered a fundamental question about advance pricing agreements (APAs): Is an APA a contract between the IRS and a taxpayer?[1] If it is a contract, is it subject to contract law? Circuit Judge John Nalbandian answered this question for the unanimous three-judge Appellate panel, opening…

Advance pricing agreement, Netherlands, Ruling, Transfer Pricing

An In-Depth Analysis of Published Anonymized APA and APA Request Summaries Under the Revised Dutch Tax Ruling Practice (Forthcoming: Intertax, vol. 49, 2021, issue 3)

Koen Bolink (Houthoff)/February 18, 2021 /Leave a comment

On 1 July 2019, the Dutch tax ruling practice was revised to align it with EU and international standards and recommendations as well as to increase its openness and transparency. In this respect, the Dutch tax authorities (DTA) now publish anonymized summaries of advance pricing agreements and advance pricing agreement (APA) requests. This month, Intertax…