Pre-filing consultation clarifies APA scope, transfer-pricing issues, and procedural requirements before a formal APA application. Pre-filing consultation for an Advance Pricing Agreement requires an applicant who has undertaken or contemplates an international transaction to request consultation in Form No. 3CEC to DGIT (International Taxation); the consultation-non-binding and consultative-will define APA scope, identify transfer-pricing issues including FAR analysis, assess suitability of the transaction for APA treatment, and discuss broad terms. For bilateral or multilateral APAs the competent authority or its representative will be associated. Form guidance requires disclosure of global group structure, associated enterprises and transaction details (anonymous requests may defer identification until formal APA application in Form No. 3CED) and functional and risk profiles.
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.
Pre-filing consultation clarifies APA scope, transfer-pricing issues, and procedural requirements before a formal APA application.
Pre-filing consultation for an Advance Pricing Agreement requires an applicant who has undertaken or contemplates an international transaction to request consultation in Form No. 3CEC to DGIT (International Taxation); the consultation-non-binding and consultative-will define APA scope, identify transfer-pricing issues including FAR analysis, assess suitability of the transaction for APA treatment, and discuss broad terms. For bilateral or multilateral APAs the competent authority or its representative will be associated. Form guidance requires disclosure of global group structure, associated enterprises and transaction details (anonymous requests may defer identification until formal APA application in Form No. 3CED) and functional and risk profiles.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
AI OCR ✕
of 
TaxTMI 
TaxTMI 
