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of <h1>Advance Pricing Agreement Sets Arm's Length Price for International Transactions; Sections 92CC(6), 92CC(7) Highlight Exceptions.</h1> An Advance Pricing Agreement (APA) is a contract between the tax authority and a taxpayer that predetermines the Arm's Length Price (ALP) or the method for determining the ALP for an international transaction. Once established, the APA is binding on both the taxpayer and the relevant tax authorities for a specified period, up to a maximum of five years. Although there is no minimum term, applications are typically for at least three years due to the resources involved. Sections 92CC(6) and 92CC(7) outline conditions where an APA may not be binding or declared void, while Rules 10Q and 10R address potential revisions or cancellations.
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