July 13, 2014
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Roll back mechanism in APA extends ALP methodology to prior years subject to conditions and procedures.
The Bill introduces a roll back mechanism to the APA scheme: an APA, subject to prescribed conditions, procedure and manner, may provide that its method for determining ALP, or the ALP itself, apply to international transactions concluded in a limited number of prior years preceding the period covered by the APA, aiming to reduce transfer pricing litigation.