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Journal articles on the topic 'Advanced pricing agreements'

Author: Grafiati

Published: 24 April 2022

Last updated: 30 July 2025

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1

Larionov, M. O. "Advanced pricing agreements: current state and prospects for Ukraine." Legal position 4 (2019): 224–29. http://dx.doi.org/10.32836/2521-6473-2019-4-224-229.

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2

Tomohara, Akinori. "Inefficiencies of Bilateral Advanced Pricing Agreements (BAPA) in Taxing Multinational Companies." National Tax Journal 57, no. 4 (2004): 863–73. http://dx.doi.org/10.17310/ntj.2004.4.05.

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3

Mescall, Devan, and Paul Nielsen. "Corporate Income Shifting in an Era of Tax Multilateralism: The Impact of Exchange-of-Information Agreements." Canadian Tax Journal/Revue fiscale canadienne 69, no. 2 (2021): 357–89. http://dx.doi.org/10.32721/ctj.2021.69.2.mescall.

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Using data from the annual reports of over 100,000 subsidiaries of multinational enterprises (MNEs) from 55 countries between 2003 and 2012, the authors of this article investigate the impact of exchange-of-information agreements ("EOI agreements") on tax-motivated income shifting. Transparency created by the signing of EOI agreements is expected to reduce the tax-motivated shifting of income by multinational corporations. Whether such agreements affect the income-shifting behaviour of multinational corporations is an unanswered question. The authors find evidence that, on average, EOI agreeme

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Silva, L., R. Curi, IF Eichhorn, and I. Coutinho. "HPR85 Opportunities of Innovative Agreements for Pricing Advanced Therapy Medicine Products (ATPM) in Brazil." Value in Health 25, no. 12 (2022): S247—S248. http://dx.doi.org/10.1016/j.jval.2022.09.1215.

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Sulik-Górecka, Aleksandra. "Tax Compliance as an Element of the Corporate Compliance Management System." Financial Sciences 26, no. 2 (2022): 44–57. http://dx.doi.org/10.15611/fins.2022.1.04.

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The aim of the paper was to identify areas of the compliance management system and assess the advisability of including tax compliance within the compliance management system. The methodology involved an analysis of relevant literature, legal acts and compliance standards. The empirical part presents the results obtained, having analysed areas of compliance management systems in a sample of ten entities listed on the WSE and included in the WIG20 index. The studied entities were found to present a variety of information on compliance management systems without taking into account the area of t

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Perčević, Hrvoje. "ANALYSIS OF THE FREQUENCY OF THE APPLICATION OF ADVANCED PRICING AGREEMENTS IN EUROPEAN UNION COUNTRIES." Ekonomska misao i praksa 31, no. 1 (2022): 163–87. http://dx.doi.org/10.17818/emip/2022/1.8.

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U ovom radu istražuje se koncentracija primjene prethodnih sporazuma o transfernim cijenama u zemljama Europske unije. Utvrđuje se imaju li zemlje Europske unije s višim bruto društvenim proizvodom više prethodnih sporazuma o transfernim cijenama na snazi u odnosu na zemlje s nižim bruto društvenim proizvodom te istražuje postojanje korelacije između broja prethodnih sporazuma o transfernim cijenama na snazi i bruto društvenog proizvoda u zemljama Europske unije. Istraživanje je obuhvatilo razdoblje od 2016. do 2019. godine, a za ostvarivanje postavljenih ciljeva istraživanja korištene su sred

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Gonçalves, Elisabete. "PP14 Value-Based Pricing For Advanced Therapy Medicinal Products: Emerging Affordability Solutions." International Journal of Technology Assessment in Health Care 38, S1 (2022): S44. http://dx.doi.org/10.1017/s0266462322001593.

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IntroductionThe emergence of advanced therapy medicinal products (ATMPs), a disruptive class of health technologies, is generating important challenges in terms of value assessment, and their high prices introduce critical access and affordability concerns.MethodsThe aim of this oral presentation is to expose the challenges of traditional value assessment and pricing and reimbursement methods in the evaluation of ATMPs, and to characterize the current and prospective financing solutions that may ensure patient access to and affordability for these health technologies.ResultsStandard health tec

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Lovdahl Gormsen, Liza, and Clement Mifsud-Bonnici. "Legitimate Expectation of Consistent Interpretation of EU State Aid Law: Recovery in State Aid Cases Involving Advanced Pricing Agreements on Tax." Journal of European Competition Law & Practice 8, no. 7 (2017): 423–36. http://dx.doi.org/10.1093/jeclap/lpx028.

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Basiashvili, Davit, and Slava Fetelava. "Legal and Practical Aspects of Cartel Detection and Prevent." New Economist 19, no. 02 (2024): 48–56. http://dx.doi.org/10.36962/nec19022024-48.

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The work deals with the practical aspects of cartels, both the legal regulation of actions restricting competition and their detection and prevention. Emphasis is placed on the role and importance of competition law in assessing the total economic damage caused by the disregard of competition law by economic agents in the relevant markets and the concerted actions of cartels. The discussion for horizontal (agreement/concerted action between competing economic agents operating in the same product market) and vertical (agreement/concerted action between non-competing economic agents operating in

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Onukwulu, Ekene Cynthia, Joyce Efekpogua Fiemotongha, Abbey Ngochindo Igwe, and Chikezie Paul-Mikki Ewim. "Strategic contract negotiation in the oil and gas sector: approaches to securing high-value deals and long-term partnerships." Journal of Advance Multidisciplinary Research 3, no. 2 (2024): 44–61. https://doi.org/10.54660/.jamr.2024.3.2.44-61.

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The oil and gas sector arecharacterized by high-stakes negotiations that require a strategic approach to securing lucrative contracts and fostering sustainable partnerships. This study examines the critical financial and strategic principles underlying large-scale contract negotiations, emphasizing methodologies that drive value optimization, risk mitigation, and long-term business success. Key negotiation strategies include leveraging market intelligence, employing structured deal frameworks, and utilizing advanced financial modeling to assess contract feasibility and profitability. A data-dr

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Schramm, Engelbert, Dennis Becker, and Michaela Fischer. "Advanced processed wastewater for different uses: constellations favouring future implementation of a multimodal water reuse concept." Journal of Water Reuse and Desalination 10, no. 4 (2020): 284–300. http://dx.doi.org/10.2166/wrd.2020.043.

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Abstract Advanced wastewater treatment is often used to produce one single water quality. In recent years, technologies have been developed that allow the production of different qualities that are fit for their purpose. These technology bundles are still not being marketed, and market requirements are unclear. Two constellations in West Basin, California and in Oman were analysed to shed light on the different constellations of actors, resource situations and institutions. The first led to the industrial reuse of several water qualities, while the second produced an application in holiday res

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Beck, Thomas J. "Education Source." Charleston Advisor 23, no. 1 (2021): 13–15. http://dx.doi.org/10.5260/chara.23.1.13.

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Education Source is an EBSCO database. It offers the user access to thousands of full-text journals and conference papers, millions of citations, thousands of abstracts, and hundreds of videos. These various print and media resources cover a wide variety of educational topics, including educational policy, pedagogy, communication and information in education, educational grants, and education economics, among many others.This database can be viewed in one of 32 languages. Documents can be found here using either a basic or advanced search, both of which are easily understandable and useable. A

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Beck, Thomas J. "Education Source Ultimate." Charleston Advisor 25, no. 3 (2024): 26–29. http://dx.doi.org/10.5260/chara.25.3.12.

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Education Source Ultimate is one of many databases offered by EBSCO. It offers access to hundreds of videos and thousands of journals and magazines on education studies, many of them full text, peer reviewed, and/or open access. These different print and media resources address numerous educational topics, including research methodology, training, assessment, literacy, technology, and ethics, among many others. This database can be viewed in any of 31 different Asian and European languages. It offers both documents and videos, often on point for the query submitted, using a standard Advanced S

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Lagae, Jean-Pierre. "Advance pricing agreements." EC Tax Review 8, Issue 1 (1999): 8–18. http://dx.doi.org/10.54648/ecta1999003.

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Khan, Mohd Anas. "RENTEASE: A MERN Stack-Based Web Application for Rental Property Management." International Journal for Research in Applied Science and Engineering Technology 13, no. 5 (2025): 2840–48. https://doi.org/10.22214/ijraset.2025.70796.

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The digital transformation of traditional industries has now extended to the real estate sector, where rental property management continues to face inefficiencies. Many processes remain fragmented, relying on outdated manual paperwork, inconsistent communication, and limited accessibility, resulting in delays, mismanagement, and frustration for landlords and tenants alike. This research introduces RENTEASE, a comprehensive web-based application developed using the MERN stack (MongoDB, Express.js, React.js, Node.js) to address these challenges. Designed as a user-centric platform, RENTEASE digi

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Raineri, Ricardo. "Power Shift: Decarbonization and the New Dynamics of Energy Markets." Energies 18, no. 3 (2025): 752. https://doi.org/10.3390/en18030752.

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This paper examines the transformative effects of decarbonization on electricity market design, emphasizing the challenges and opportunities posed by the rapid integration of renewable energy sources such as wind and solar. It analyzes the evolution of key wholesale market segments—including day-ahead, real-time, capacity, long-term purchase agreements, ancillary services, and transmission markets—highlighting their critical roles in managing the variability of renewable energy generation through efficient price signals and resource coordination. Variable renewable energy integration introduce

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Hummel, Katrin. "Advance Pricing Agreements (APA)." Controlling 21, no. 7 (2009): 412–13. http://dx.doi.org/10.15358/0935-0381-2009-7-412.

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18

Desmet, Thomas, Sissel Michelsen, Elena Van den Brande, Walter Van Dyck, Steven Simoens, and Isabelle Huys. "OD28 Towards Implementing New Payment Models For The Reimbursement Of High-Cost, Curative Therapies: Insights From Semi-Structured Interviews." International Journal of Technology Assessment in Health Care 40, S1 (2024): S45—S46. https://doi.org/10.1017/s0266462324001594.

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IntroductionIn response to the intricate challenges posed by high-cost, one-shot curative therapies, this study explores what hinders the wide implementation of innovative payment schemes across Europe. Drawing insights from the Belgian social healthcare system, this study focused on defining the necessary and sufficient conditions for implementing outcome-based spread payments in the context of market access to advanced medicinal productsMethods Semi-structured interviews (n=33) were conducted with physicians (n=2), hospital pharmacists (n=4), hospital managers (n=2), patient representatives

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Imamović-Čizmić, Kanita. "The Artificial Intelligence and Competition Law - Challenges for Bosnia and Herzegovina." European Integration Studies 1, no. 16 (2022): 166–76. http://dx.doi.org/10.5755/j01.eis.1.16.31225.

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The digital economy is characterized by new business models based on the use of electronic communications and digital technology for the production and distribution of goods and services. Big data is becoming an invaluable resource in the functioning of the digital economy. In order to survive in the market and be more competitive, firms are changing the way they make their strategic decisions and are increasingly resorting to the use of big data and technologically advanced tools, such as pricing algorithms. Companies increasingly use computer algorithms to improve their pricing models, adjus

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Ganpati Goel and Rahul Bhramhabhatt. "Dual sourcing strategies." International Journal of Science and Research Archive 13, no. 2 (2024): 4357–76. https://doi.org/10.30574/ijsra.2024.13.2.2155.

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The dual-sourcing strategy of Tesla is vital for gaining a competitive edge and operational efficiency in the electric vehicle (EV) market. While both TSLA and NOT share procurement of critical components like balance rings with a few suppliers and not just one, Tesla mitigates geopolitical tensions, tariffs, and supply disruptions by procuring critical components from various suppliers. By strategically increasing the diversification in its supply chain, it has a consistent stream of suppliers that provide services continually, even in the face of global fluctuations like the COVID-19 pandemi

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Devrim Askin, Mehmet. "Advance Pricing Agreements in Turkey." Intertax 37, Issue 12 (2009): 701–8. http://dx.doi.org/10.54648/taxi2009072.

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The introduction of new legislation on transfer pricing paved the way for taxpayers to enter into binding agreements with the Turkish Ministry of Finance (MoF) for the first time. This article will give a brief description of legislative changes and then provide a snapshot of Advance Pricing Agreement (APA) regime in Turkey.

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Valente, Piergiorgio. "Advance Pricing Arrangements: Optimal Tool – Optimal Framework?" Intertax 48, Issue 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 Resol

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23

Kumar, Amit. "Development and Implementation of a “Real Estate Web Application” for Modern Web Application." International Journal for Research in Applied Science and Engineering Technology 12, no. 11 (2024): 437–41. http://dx.doi.org/10.22214/ijraset.2024.64990.

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A real estate management system is one of the modern software solutions developed to keep up and improve on the management and operating process within the real estate industry. Real estate is one of the fastest-growing industries on a global level and thousands of properties are issued every day, which calls for effective automation in some property management activities. REMS has solutions to all these issues in the very complete system platform that encompasses various aspects of property management, such as placement, tenant management, tracking of finances, and scheduling of maintenance.

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24

Bergquist, Philip J. "Experience concerning advance pricing agreements." Intertax 20, Issue 6/7 (1992): 387–402. http://dx.doi.org/10.54648/taxi1992055.

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Stiastny, Marion, and Ina Kerschner. "The Experience with Advance Pricing Agreements." Intertax 41, Issue 11 (2013): 588–93. http://dx.doi.org/10.54648/taxi2013056.

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In times of increasing cross-border transactions, multinational enterprises are faced with the obstacle of rising legal uncertainty and therefore reduced planning reliability in tax matters. Advance pricing agreements (APAs) provide an appropriate means of tackling such problems relating to transfer pricing issues. In the last two decades APAs have risen from relative obscurity to become an important transfer pricing controversy management tool, offering benefits to taxpayers as well as tax administrations. These issues are dealt with in Markham's study, Advance Pricing Agreements - Past, Pres

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Bolink, Koen. "Country Note: An In-Depth Analysis of Published Anonymized APA and APA Request Summaries Under the Revised Dutch Tax Ruling Practice." Intertax 49, Issue 3 (2021): 278–91. http://dx.doi.org/10.54648/taxi2021024.

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On 1 July 2019, the Dutch tax ruling practice was revised to align it with EU and international standards and recommendations and to increase its openness and transparency. In this respect, the Dutch tax authorities now publish anonymized summaries of Advance Pricing Agreements and Advance Pricing Agreement requests. The country note provides an in-depth analysis of all sixty-six anonymized summaries published during the first year after the introduction of the revised Dutch tax ruling practice and highlights and analyses the most significant cases. This provides further insight into the pract

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Becker, Johannes, Ronald B. Davies, and Gitte Jakobs. "The economics of advance pricing agreements." Journal of Economic Behavior & Organization 134 (February 2017): 255–68. http://dx.doi.org/10.1016/j.jebo.2016.12.019.

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Szymczak, Magdalena. "Uprzednie porozumienia cenowe w Polsce i innych państwach członkowskich Unii Europejskiej." Optimum Economic Studies, no. 1(107) (2022): 142–57. http://dx.doi.org/10.15290/oes.2022.01.107.10.

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Purpose – Indicating the Advance Pricing Agreement (APA) as a tool to help taxpayers in reducing tax risk and assessing the functioning of APAs in Poland compared to other European Union Member States through the prism of the time of negotiations. Research method – The analysis of empirical data (from the period 2015–2019), the analysis of legal acts in economic terms, studies of the literature on the subject. Results – Advance Pricing Agreements, as a tax risk minimization tool, have been in force in Poland for a relatively short period of time. The analysis covered data from 5 years. This en

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Herath, Siriyama Kanthi, and John H. Young. "A review of advanced pricing agreement recommendations." International Journal of Critical Accounting 4, no. 3 (2012): 336. http://dx.doi.org/10.1504/ijca.2012.047367.

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De Waegenaere, Anja, Richard Sansing, and Jacco L. Wielhouwer. "Using Bilateral Advance Pricing Agreements to Resolve Tax Transfer Pricing Disputes." National Tax Journal 60, no. 2 (2007): 173–91. http://dx.doi.org/10.17310/ntj.2007.2.01.

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Lutsyk, Anatolii, and Andrii Sorokivskyi. "Advance pricing agreement in the fiscal policy of Ukraine." Economic Analysis, no. 34(3) (2024): 334–41. https://doi.org/10.35774/econa2024.03.334.

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Advance pricing agreements are a key component of fiscal policy implementation and an effective means of fiscal regulation of transfer pricing, aimed at avoiding potential tax disputes, as well as compliance with the requirements of tax legislation regarding cross-border transactions. The article describes a comparative analysis of international practices of advance pricing arrangement, provides an overview of the relevant regulatory framework that regulates this procedure in Ukraine, as well as the classification and procedural stages of pricing arrangement. The article notes the main advanta

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AULIA, SESARIO. "ADVANCE PRICING AGREEMENT DALAM PERSPEKTIF HUKUM PERJANJIAN." Al-Syakhsiyyah: Journal of Law & Family Studies 2, no. 1 (2020): 134–49. http://dx.doi.org/10.21154/syakhsiyyah.v2i1.2164.

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ABSTRAK : Menurut Pasal 1 Ayat (5) Peraturan Menteri Keuangan Republik Indonesia Nomor 22/PMK.03/2020 tentang Kesepakatan Harga Transfer (Advance Pricing Agreement) yang selanjutnya disebut APA adalah Perjanjian Tertulis antara Direktorat Jenderal Pajak dan Wajib Pajak atau Direktorat Jenderal Pajak dengan otoritas pajak pemerintah Mitra P3B yang melibatkan wajib pajak untuk menyepakati kriteria - kriteria dalam penentuan harga transfer dan/atau menentukan harga wajar atau laba wajar dimuka. Latar Belakang adanya APA adalah untuk mencegah praktek transfer pricing yang sudah menjadi masalah glo

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de Carolis, Daniele. "Critical Assumptions in Advance Pricing Agreements: A Comparison between the OECD Guidelines and the American Tax System." Intertax 41, Issue 12 (2013): 676–81. http://dx.doi.org/10.54648/taxi2013065.

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According to the OECD Guidelines, critical assumptions hold fundamental importance within the discipline of advance pricing agreements. Nonetheless, only a few countries provided detailed rules on this aspect in their national legislation on advance pricing agreements. In order to urge national legislators to pay greater attention to this crucial aspect of advance pricing agreements, this article will first look at how critical assumptions are dealt with in the OECD Guidelines; then, it will analyse the discipline of critical assumptions in one of the jurisdictions with the longest and most si

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Mahajan, Kartikey, and Jasmeet Singh. "Advance Pricing Agreements: The Way Forward for India." Intertax 38, Issue 6/7 (2010): 378–83. http://dx.doi.org/10.54648/taxi2010041.

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This article critically examines the importance attached to the introduction of Advance Pricing Agreements (APAs) in India under the upcoming Direct Taxes Code. After evaluating the types, constituents, and procedure of an APA and comparing the international standards adopted by many countries, the authors try to highlight the best possible APA mechanism that can best serve the needs of India-related transactions. Thus, the authors try to highlight the modifications required in the provision related to APA under the Direct Taxes Code, which will lead to an effective implementation of the APA p

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Dewi Astuti, Melani. "Country Note: Implementation of BEPS Recommendations in Indonesia’s New APA and Transfer Pricing Rules." Intertax 48, Issue 12 (2020): 1145–54. http://dx.doi.org/10.54648/taxi2020114.

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Indonesia has recently updated its Advance Pricing Agreement and transfer pricing regulations in order to capture the development in the business and transfer pricing. It is also aimed to align with the Base Erosion and Profit Shifting (BEPS) recommendations. The new regulation has made substantial changes to the old advance pricing agreements (APAs) and transfer pricing regulations. With regards to transfer pricing, the new regulation has made some changes pursuant to the related parties’ definition, transfer pricing methods, comparability analysis procedures, special transactions, and intang

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Eden, Lorraine, and William Byrnes. "Transfer pricing and state aid: The unintended consequences of advance pricing agreements." Transnational Corporations 25, no. 2 (2018): 9–36. http://dx.doi.org/10.18356/7fb86b3d-en.

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Szymczak, Magdalena. "Good practice for transfer pricing in selected OECD countries." Prace Naukowe Uniwersytetu Ekonomicznego we Wrocławiu 64, no. 9 (2020): 119–30. http://dx.doi.org/10.15611/pn.2020.9.09.

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Over the past decades the use of transfer pricing has increased significantly. It was noted that transfer pricing impacts on many areas of enterprise management. Countries, observing the gravity of the issue and taking care of securing their tax base, began to adopt regulations governing this matter. To meet the needs of both enterprises and regulators, international organisations have been working on developing guidelines and promoting them to adopt regulations on transfer pricing that are as clear and transparent as possible. Good practices included in the OECD Guidelines have become the mos

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Szymczak, Magdalena. "Good practice for transfer pricing in selected OECD countries." Prace Naukowe Uniwersytetu Ekonomicznego we Wrocławiu 64, no. 9 (2020): 119–30. http://dx.doi.org/10.15611/pn.2020.9.09.

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Over the past decades the use of transfer pricing has increased significantly. It was noted that transfer pricing impacts on many areas of enterprise management. Countries, observing the gravity of the issue and taking care of securing their tax base, began to adopt regulations governing this matter. To meet the needs of both enterprises and regulators, international organisations have been working on developing guidelines and promoting them to adopt regulations on transfer pricing that are as clear and transparent as possible. Good practices included in the OECD Guidelines have become the mos

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Öner, Cihat. "Legal Nature of Advance Pricing Agreements under Turkish Law: A Comparative Analysis." Intertax 40, Issue 8/9 (2012): 503–13. http://dx.doi.org/10.54648/taxi2012050.

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This article first identifies and defines the legal nature of advance pricing agreements on a theoretical basis using the criteria developed in the literature and case law for administrative contracts. It then underlines and assesses the impact of case law on the definition of an administrative contract using a comparative approach. The general research question is whether these criteria can be employed to determine the legal nature of advance pricing agreements under Turkish law.

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Katsushima, Toshiaki. "Hybrid Bilateral Advance Pricing Agreements: The Trend for the Future?" Intertax 25, Issue 1 (1997): 2. http://dx.doi.org/10.54648/taxi1997001.

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van der Ham, Susann, and Steffen Voll. "Erweiterte Bindungswirkung von Vorabzusagen im Rahmen von Advance Pricing Agreements." Die Unternehmensbesteuerung 6, no. 4 (2013): 219–33. http://dx.doi.org/10.9785/ubg-2013-060404.

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Tarigan, Therecia Fransisca. "Advance Pricing Agreement between Multinational Companies and the Government of Indonesia in the perspective of Indonesian Tax Law." SALAM: Jurnal Sosial dan Budaya Syar-i 9, no. 2 (2022): 535–48. http://dx.doi.org/10.15408/sjsbs.v9i2.25124.

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APA (Advance Pricing Agreement) is an agreement between the Directorate General of Taxes and Taxpayers and/or other country's tax authorities to agree on the criteria and/or determine the fair price or fair profit in advance of the parties who have a Special Relationship. APA generally occurs between Tax Authorities and Multinational Enterprises. The purpose of APA is to provide facilities for taxpayers to resolve transfer pricing problems. Transfer pricing is a company policy in determining the transfer price of a transaction, be it goods, services, intangible assets, or financial transaction

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Lazuardi, Agnes. "Implementation of Advance Pricing Agreement Regulation as Transfer Pricing Dispute Prevention in Indonesia." International Journal of Scientific and Research Publications (IJSRP) 12, no. 2 (2022): 260. http://dx.doi.org/10.29322/ijsrp.12.02.2022.p12238.

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Rasch, Stephan. "Advance Pricing Agreements: Vorabverständigungsverfahren i.S.d. § 89a AO – Konkretisierung durch den Anwendungserlass." Internationale SteuerRundschau 13, no. 8 (2024): 261–68. http://dx.doi.org/10.9785/isr-2024-130801.

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Zusammenfassung Bereits im Jahr 2021 hat der Gesetzgeber im Abzugsteuerentlastungsmodernisierungsgesetz (AbzStEntModG) eine gesetzliche Regelung für die sog. Vorabverständigungsverfahren („Advance Pricing Agreements“ - APA) in § 89a AO eingeführt. Mit dieser Regelung wird erstmals eine eigenständige, nationale Rechtsgrundlage für die Streitbeilegung bei drohender Doppelbesteuerung geschaffen. Bis zu diesem Zeitpunkt im Jahr 2021 gab es lediglich ein Merkblatt aus dem Jahr 2006, auf dessen Basis (unter Berufung auf Art. 25 OECD-MA nachgebildete Artikel im jeweiligen DBA) Vorabverständigungsverf

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Park, Min. "U.S. Advance Pricing Agreement: An Option to Resolve International Tax Dispute in Transfer Pricing Cases." International Area Review 1, no. 1 (1997): 115–33. http://dx.doi.org/10.1177/223386599700100108.

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Obtaining a preliminary approval from its tax authority as to its mehodologies of transfer pricing would provide taxpayers with a safe harbor. This preliminary measure provides positive assurance against unexpected income allocation adjustments made by the tax authority. Such a procedure is commonly referred to as an “Advance Pricing Agreement(APA).” In order to be an effective income allocation method, an APA must be an either binational or multinational. Only binational or multinational APA could supplement the judicial, administrative, and treaty mechanisms for resolving transfer pricing is

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Marcelino, Ernie. "Analysis of the Application of Mutual Agreement Procedure (MAP) and Advance Pricing Agreement (APA) in Indonesia." International Journal of Scientific and Research Publications (IJSRP) 11, no. 1 (2020): 552–55. http://dx.doi.org/10.29322/ijsrp.11.01.2021.p10964.

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Vollert, Pia, Carolin Eikel, and Caren Sureth. "Advance Pricing Agreements (APAs) als Instrument zur Vermeidung von Verrechnungspreiskonflikten – eine kritische Betrachtung." Steuer und Wirtschaft - StuW 90, no. 4 (2013): 367–79. http://dx.doi.org/10.9785/stuw-2013-900405.

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Afik, Zvika, and Yaron Lahav. "Risk Transfer Valuation in Advance Pricing Agreements Between Multinational Enterprises and Tax Authorities." Journal of Accounting, Auditing & Finance 31, no. 2 (2015): 203–11. http://dx.doi.org/10.1177/0148558x15571734.

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Olika, Daniel, and Ilemobade Olateru-Olagbegi. "Assessing the Transfer Pricing Disputes Framework in Nigeria." Business Law Review 43, Issue 2 (2022): 65–76. http://dx.doi.org/10.54648/bula2022010.

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Transfer pricing, from documentation to audit, can be complicated and costly. Despite the release of transfer pricing regulations and increased scrutiny over intercompany dealings, the revenue authorities and taxpayers still disagree over various aspects of transfer pricing documentation. This situation necessitated the creation of various transfer pricing dispute resolution and dispute prevention mechanisms in jurisdictions across the globe. The Organization for Economic Cooperation and Development (OECD) has set the global standards on the mechanisms for transfer pricing dispute resolution/p

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Saragi, Daniel Edgar Hirasma. "DEVELOPMENT OF TRANSFER PRICING REGULATIONS IN INDONESIA." Jurnal Ilmu Ekonomi dan Pembangunan 24, no. 2 (2024): 77. https://doi.org/10.20961/jiep.v24i2.90934.

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This research driven by the urgency to understanding the massive improvement of transfer pricing regulations in Indonesia. Directorate General of Taxes (DGT) have adjusted along with the advancement of macroeconomic, business field, cross border trade, and domestic needs. This study aims to describe the development of transfer pricing regulations in Indonesia, since it was first enacted in 1983. The analysis covers three main topics, which are the implementation and examination of arm's length principle, transfer pricing documentation, and advance pricing agreement. This research used qualitat

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