Advance Pricing Agreement pre-filing meeting outlines applicant requirements and documentation necessary to initiate APA discussions. The form sets out requirements for a pre-filing meeting to obtain an Advance Pricing Agreement, including applicant identification, group and associated ... Summary
Advance Pricing Agreement pre-filing meeting outlines applicant requirements and documentation necessary to initiate APA discussions.
The form sets out requirements for a pre-filing meeting to obtain an Advance Pricing Agreement, including applicant identification, group and associated enterprise details, a three year business and functional profile, full disclosure of international transactions to be included or excluded, the proposed APA type and jurisdictions, years sought including rollback, prior transaction values, the proposed transfer pricing methodology with comparables and arm's length indicators, critical assumptions, histories of competent authority and audit interactions, and names of representatives for discussions.
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