Academic literature on the topic 'Advance pricing arrangements'
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Journal articles on the topic "Advance pricing arrangements"
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Valente, Piergiorgio. "Advance Pricing Arrangements: Optimal Tool – Optimal Framework?" Intertax 48, Issue 1 (January 1, 2020): 67–73. http://dx.doi.org/10.54648/taxi2020005.
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Advance Pricing Agreements (APAs) are a diffused tool for taxpayers to obtain certainty in relation to the tax impact of their cross-border activities through an agreement with a tax administration in advance of such activities. APAs can be unilateral, bilateral, or multilateral depending on the number of national tax administrations involved, the latter two promising that the agreement made shall not be questioned in the other affected tax jurisdiction. Departing from the enhanced mutual agreement procedure (MAP) framework recently established among Member States through the Tax Dispute Resolution Directive, a future EU legislative initiative could outline a robust framework for MAP APAs in the Single Market. Advance Pricing Arrangements, Dispute resolution, MAP – Mutual agreement procedures, Administrative Cooperation, BEPS, Transparency, Fiscal Stateaid, Transfer Pricing
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Kuropka, Karolina. "Advance Pricing Arrangements as a Tax Strategy Tool for Related Entities." European Financial and Accounting Journal 15, no. 2 (December 15, 2020): 31–44. http://dx.doi.org/10.18267/j.efaj.240.
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Brodzka, Alicja. "Better governance through more transparency on advance cross-border tax rulings." Journal of Governance and Regulation 6, no. 1 (2017): 7–11. http://dx.doi.org/10.22495/jgr_v6_i1_p1.
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In recent years, the challenge posed by tax fraud and tax evasion has increased considerably and has become a major concern within the European Union. As a consequence, in the European initiatives a special emphasis has been laid on the actions aimed at reinforcing the anti-abuse provisions in bilateral tax treaties, national legislation and EU corporate legislation. Any artificial arrangement carried out for tax avoidance purposes would be ignored and companies would be taxed instead on the basis of actual economic substance. The aim of the article is presenting the European initiative aimed at implementing the automatic mode of the exchange of information on cross-border tax rulings and advance pricing arrangements. The paper investigates if the implemented measure can help Member States to detect certain abusive tax practices taken by companies, and to take the effective actions in response. It also tries to answer the question whether the initiative can result in more transparency and – as a consequence – in much better governance, both at the states’ and the corporations’ level.
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Borkowski, Susan C. "The history of PATA and its effect on advance pricing arrangements and mutual agreement procedures." Journal of International Accounting, Auditing and Taxation 17, no. 1 (January 2008): 31–50. http://dx.doi.org/10.1016/j.intaccaudtax.2008.01.004.
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KOSCHUK, Tetiana. "Agreements between tax authorities and taxpayers in the context of EU law on state aid." Fìnansi Ukraïni 2021, no. 1 (March 18, 2021): 64–82. http://dx.doi.org/10.33763/finukr2021.01.064.
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This article analyses how the application of the EU legislation on state aid has impacted the development of cooperation between tax authorities and taxpayers through the various forms of agreements they enter into. These measures of tax administration may qualify as state aid to business entities only if they meet all the criteria for such aid, namely: they should offer an economic advantage to the beneficiary; they should be granted by the state or through state resources; they should be selective; they should distort competition and have an adverse impact on trade. Furthermore, there are some areas to which the general rules of state aid do not apply. The latter include, among others, the operations of agricultural industries and the actions the state is obliged to take under international treaties. The analysis of the European Commission's approaches and case law has given rise to the following conclusions: 1) the write-off, instalment and deferral arrangements for the tax debt of insolvent economic entities will qualify for state aid only if it is proven that more funds would have made it into the budget had the corresponding agreements not been in place (in particular, if the taxpayer had gone bankrupt); 2) to recognize the consequences of the violation of transfer pricing rules as state aid when entering into advance pricing agreements, it is crucial to unequivocally prove that tax legislation has been violated and prove that, in view of all other opportunities for taxation under the "standard" conditions, the company has in fact paid less taxes; 3) involvement in joint legal compliance programs will not be considered a provision of state aid if the terms of such cooperation provide only procedural benefits to the parties to the agreements, rather than entailing any reduced tax liability for a business entity.
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Aidelojie, Kenneth. "Multilateral Organisations,Fossil Fuels and Energy Law and Policy: The Tower of Babel Re–visited." European Energy and Environmental Law Review 17, Issue 4 (August 1, 2008): 227–55. http://dx.doi.org/10.54648/eelr2008021.
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In recent weeks, it appears that regulatory and related policy interest in OPEC and other oil producers rises in direct proportion to the price of oil. On 26–27 June, European Union representatives will be travelling to Siberia in order to seek new regulatory arrangements on oil and gas imports, as well as concessions in relation to Western European investment in the Russian energy sector. Prime Minister Gordon Brown is in Saudi Arabia, seeking regulatory concessions related to higher production levels for oil in order to force prices down. Against this backdrop, he has threatened to spend up to £100 billion (C=127 billion) weaning citizens off the expensive energy imports that threaten family budgets. Similarly, in the recent presidential primaries in the United States, Hillary Clinton promised to bring legal action against OPEC in relation to its cartel status. Notwithstanding the implicit evidence of the weak bargaining power of consumer nations that are forced to visit producer nations for “constructive talks, there is much to commend scholarly attention to the role of regional and multilateral institutions in relation to fossil fuels regulation at this time. This article analyses the role of these institutions (Section 1) particularly in relation to OPEC, against the backdrop of the energy dependency (Section 2) that has evolved among leading oil consumer nations. In Section 3, we scrutinize dual energy pricing, as well as the trade compatibility of one of the EU’s answers to oil dependency, the Renewable Energy Sources Directive. We then proceed to analyse unilateral and multilateral litigation prospects in respect of OPEC’s export regulatory control practices (Section 4) prior to offering some constructive concluding remarks. In view of the current third wave international energy crisis, it is right that multilateralism should serve as a sensible way forward given the abject failure of individual consumer states thus far to both advance a sustainable energy security regulatory and policy framework and, in an integrated fashion, to address the challenges of climate change.
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Markham, Michelle. "Advance Pricing Arrangement Reform in Australia: Was It Worth the Wait?" Intertax 40, Issue 1 (January 1, 2012): 63–74. http://dx.doi.org/10.54648/taxi2012006.
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In June 2007, the Australian Taxation Office (ATO) announced that it had tendered for an independent review to evaluate the role and performance of its Advance Pricing Arrangement (APA) Program. Following the submission of the Review Report in 2008, the ATO took steps to co-design, together with industry representatives, a more efficient and effective system that would satisfy the needs of both internal and external stakeholders and be sustainable in the long term. The revitalized APA Program was finally introduced in March 2011. This article will discuss and analyse the efficacy of the changes brought about by the new Program.
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Koo, Hui-Wen, and Chun-Chieh Wang. "Indexed Pricing: Sugarcane Price Guarantees in Colonial Taiwan, 1930–1940." Journal of Economic History 59, no. 4 (December 1999): 912–26. http://dx.doi.org/10.1017/s0022050700024074.
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In Taiwan during the Japanese colonial period, sugarcane was typically purchased by Japanese-owned sugar mills at prices guaranteed long in advance of delivery. In some places, the future price was indexed to the price of rice in the following year. This study points out that indexing served to insure farmers' real incomes. But as an insurance against an aggregate risk, this arrangement threatened the mill's profits. We investigate why mills nevertheless offered the insurance.
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Rhyn, Jacques van, and Janelle Sadri. "LNG pricing trends and key considerations." APPEA Journal 55, no. 2 (2015): 417. http://dx.doi.org/10.1071/aj14052.
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Historically, LNG has been sold through long-term contracts with limited flexibility in volume and price. LNG trade patterns have evolved significantly, adding to increased sales of multiple cargoes on the spot market, brokered trades and speculative trading positions being taken up by non-traditional players. Buyers in the Asia-Pacific region are keen to secure supply for local markets, while Australian producers, particularly subsidiaries of foreign headquartered groups, are under pressure to sell at competitive prices. From a transfer pricing perspective, the Australian Taxation Office (ATO) has placed increased scrutiny on the commerciality of arrangements, arm’s length outcomes and profit allocations between Australian taxpayers and their international related parties (e.g. marketing and trading hubs). This extended abstract covers: factors that could impact on the selection of a price index and the slope or gradient to be applied in pricing formulae; blended pricing based on an average of different indices, and why pooling and trading may make commercial sense, although revenue authorities may not look favourably upon it; the importance of the contractual terms, the market situation and the other commercial contract conditions on the pricing of related-party LNG sales; and, the value in potentially seeking an advanced pricing agreement in a related party LNG pricing context, given the significance of the transactions. Given the practical and commercial challenges facing the industry and with several projects commencing production in the relatively near future, this is very topical. The authors use case studies to illustrate the key concepts.
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Adesi, Michael, De-Graft Owusu-Manu, and Roisin Murphy. "Strategic competences for pricing quantity surveying consultancy services." Engineering, Construction and Architectural Management 25, no. 3 (April 16, 2018): 458–74. http://dx.doi.org/10.1108/ecam-12-2016-0264.
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Purpose Professional quantity surveying (QS) services are critical to successful delivery of construction projects within planned budget, quality and duration. The supply of QS professional services is largely dependent on the price level of services and the willingness of clients to pay. The pricing of professional QS consultancy services has been confronted with a myriad of pricing challenges due to rapid changes in the business environment; the pervasive influence of information technology; and the complexity of clients’ expectation. It is therefore necessary for QS consultancy firms to develop strategic competences for the pricing of their services. In addition, numerous studies have not given the pricing the pricing of professional services the requisite attention. The purpose of this paper is to investigate the strategic competences for pricing professional QS services. Design/methodology/approach The study was positioned within the positivist tradition. As a result, the quantitative approach was adopted using a survey questionnaire to collect data from QS consultants. The sample size of the study was 79 professional quantity surveyors chosen by using simple random sampling technique from a population of 372 registered professional QS of the Ghana Institution of Surveyors. Using the χ2 test and factor analysis, the study established relationship between strategic competences and pricing of QS services. Findings The study found that strategic competences for pricing QS professional services is significantly related to the managerial and professional competence of QS consultants. The strategic competences of QS consultants identified by this study include business management, services cost management; and production capabilities. Practical implications This study provides an empirical basis for QS consultancy firms to focus on strategic direction of their contractual arrangement with clients. Practically, resource configuration and on strategic competences for professional service pricing would create price leadership. Originality/value The study advances the pricing knowledge within the QS practice by demonstrating the nexus between strategic competences and the pricing of QS professional services which hitherto this study have not been effectively investigated.
Dissertations / Theses on the topic "Advance pricing arrangements"
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Wedin, Axel. "Advanced Pricing Arrangements : Development of the Swedish legislation." Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Rättsvetenskap, 2012. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-19001.
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In recent years transfer pricing has become one of the most important issues for tax authorities and companies. As the area has become more complex this has lead to an increase in disputes and a need for dispute resolution procedure. Advanced Pricing Arrangement (APA) is the latest dispute resolution procedure and was introduced in Sweden in 2010. APAs determine a taxpayer’s future taxation of cross-border transaction by a taxpayer. Through co-operation the taxpayer and the tax authorities reach an APA that aims to avoid double taxation. The legislation is based on the guidance from the Organization for Economic Co-operation and Development (OECD) and it serves as a framework for many domestic legislations. Other countries with more experience from APAs have implemented additional guidance from the OECD in its legislation but the Swedish legislation has left some options outside. The Swedish APA does not allow for unilateral APAs where an agreement is concluded only with one tax authority in a cross-border transaction. In Sweden, only APAs negotiated with other tax authority are allowed. To increase legal certainty where unilateral APAs are the best or only way Sweden should implement them it its legislation. As the APA process is costly and complex small and medium companies cannot benefit from the advantages. In order for smaller companies to be able to take advantage of the APA program a simplified system should be implemented. In some countries the tax administrations also allows the APA to be applicable retrospective, referred to as roll-back. Through a roll-back taxpayers can avoid potential disputes regarding past transactions as well as the advantages from the APA for future transactions. This can be done while a taxpayer is under audit and is considered a less hostile alternative.
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Maděrová, Petra. "Zákonná aplikace transferových cen v podnikové praxi." Master's thesis, Vysoká škola ekonomická v Praze, 2010. http://www.nusl.cz/ntk/nusl-75689.
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The diploma paper was focused on analysis of the tools -- it means documentation of transfer pricing and advance pricing arrangement leading to the higher tax bond of tax subject, for example: in the case of tax control. The main benefit of this diploma paper consists of analysis of primary data. These data were obtained from the questionnaire as well as from the interviews oriented mainly on tax control which I had led with 2 multinational companies. The questionnaire, which I had done by myself, was sent to 46 multinational companies which their business platforms are located also in the Czech Rep. The most valuable written sources from which some data for my diploma paper were taken is the real documentation of transfer pricing done for the request of advance pricing arrangement as well as the decision of tax administrator in the same case according to the § 38nc Law N. 586/1992 Sb., about income tax. Just the character of the data guarantees the practical application of this diploma paper. I hope according to my diploma paper to be successful in notice of absence in the basic instruments of transfer pricing from point of the multinational companies view which could lead to the adjustment by competent authorities. This adjustment could consequently improve the cooperation between tax subjects and tax authorities.
Book chapters on the topic "Advance pricing arrangements"
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"Annex II to Chapter IV. Guidelines for Conducting Advance Pricing Arrangements under the Mutual Agreement Procedure (MAP APAs)." In OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 471–500. OECD, 2017. http://dx.doi.org/10.1787/tpg-2017-20-en.
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