Advance Pricing Agreement certainty secured, offering pre-agreed transfer pricing methods and retrospective rollback relief for taxpayers. The APA mechanism specifies transfer pricing methods and determines the Arm's Length Price for international transactions prospectively for up to five years and permits optional rollback for four preceding years, thereby extending pricing certainty for taxpayers across a range of sectors and transaction types.
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 Agreement certainty secured, offering pre-agreed transfer pricing methods and retrospective rollback relief for taxpayers.
The APA mechanism specifies transfer pricing methods and determines the Arm's Length Price for international transactions prospectively for up to five years and permits optional rollback for four preceding years, thereby extending pricing certainty for taxpayers across a range of sectors and transaction types.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.