Advance pricing agreements fix arm's length pricing and bind taxpayers and tax authorities under prescribed procedural conditions. Advance pricing agreements allow the tax authority, with executive approval, to determine the arm's length price for international transactions or the income attributable to operations in the jurisdiction; such agreements govern determination irrespective of other methods, are binding on the taxpayer and tax officers for up to five consecutive tax years, may cover specified prior years, and can be rendered non-binding by change in law or facts or declared void for fraud or misrepresentation, with corresponding adjustments to limitation periods.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Advance pricing agreements fix arm's length pricing and bind taxpayers and tax authorities under prescribed procedural conditions.
Advance pricing agreements allow the tax authority, with executive approval, to determine the arm's length price for international transactions or the income attributable to operations in the jurisdiction; such agreements govern determination irrespective of other methods, are binding on the taxpayer and tax officers for up to five consecutive tax years, may cover specified prior years, and can be rendered non-binding by change in law or facts or declared void for fraud or misrepresentation, with corresponding adjustments to limitation periods.
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