Warning

Info

Warning

Info

Warning

Info

LSDefine

Simple English definitions for legal terms

advance pricing agreement

Read a random definition: personal-holding-company tax

A quick definition of advance pricing agreement:

An advance pricing agreement is a deal made between a big company that operates in different countries and the tax authorities of those countries. The agreement decides how the company will calculate the prices of goods or services that it transfers between its different branches in different countries. The purpose of the agreement is to avoid double taxation, which means paying taxes twice on the same income. There are different types of advance pricing agreements, depending on how many tax authorities are involved. However, if a tax authority is not part of the agreement, it can still decide to tax the company differently.

A more thorough explanation:

An advance pricing agreement (APA) is a binding arrangement made between a multinational company and one or more national tax authorities. The purpose of this agreement is to determine the method that the company will use to calculate transfer prices, with the aim of reducing or eliminating double taxation.

There are three types of APAs:

  • Unilateral APA: An agreement made between a company and one tax authority.
  • Bilateral APA: An agreement made between a company and two tax authorities.
  • Multilateral APA: An agreement made between a company and more than two tax authorities.

It's important to note that a tax authority that is not a party to the agreement is not bound by the transfer-pricing method specified in the agreement.

Let's say a multinational company has subsidiaries in two countries, Country A and Country B. The company wants to ensure that it doesn't pay taxes on the same income twice, so it enters into a bilateral APA with the tax authorities in both countries. The APA specifies the transfer-pricing method that the company will use to calculate the prices at which it transfers goods or services between its subsidiaries in Country A and Country B.

Another example could be a company that operates in multiple countries and wants to avoid disputes with tax authorities over transfer pricing. The company could enter into a multilateral APA with the tax authorities in all the countries where it operates. The APA would specify the transfer-pricing method that the company will use to calculate the prices at which it transfers goods or services between its subsidiaries in different countries.

These examples illustrate how APAs can help multinational companies avoid double taxation and reduce the risk of disputes with tax authorities over transfer pricing.

advance premium | advancing market

Warning

Info

General

General chat about the legal profession.
main_chatroom
👍 Chat vibe: 5 👎
Help us make LSD better!
Tell us what's important to you
HopefullyInLawSchool
16:17
Possibly
RoaldDahl
16:26
Cool
RoaldDahl
16:26
thank you!!!! i hope it means something
pinkandblue
16:31
fart
IrishDinosaur
16:36
Mich R gang lesgooo
Did anyone else get that random get to know nova email?
HopefullyInLawSchool
17:21
Ya it was sent to all YM applicants
starfishies
17:37
Anyone get the NDLS email inviting you to apply for something even though they haven’t made a decision on your app yet
17:38
Better yet I got the email and I was rejected last month
starfishies
17:38
Wtf
starfishies
17:39
and the deadline is in like a week what is this
any cardozo movement?
BatmanBeyond
18:01
Sent a LOCI via portal, but I'm wondering if email would have gotten me a swifter response
BatmanBeyond
18:02
This whole hold/wait-list/reserve system is a headache
loci already?
BatmanBeyond
18:09
If the odds are like 1-2% I don't think it matters much by the numbers
12:11
I got the same NDLS email
OrangeThing
12:18
I think the user profiles are broken
19:29
Any word out of Notre Dame?
19:29
Only the invitation to apply for LSE
19:29
Anyone received a decision from NDLS?
19:50
when did u guys apply that just heard from umich? they havent even glanced at my app yet
0:30
how am i supposed to spy on people when profile links are broken?
Right. Broken links smh
I've been UR since first/second week of Jan, no updates otherwise, is that a bad sign? At or above median LSAT and above 75th gpa.
The profile links are not working for me. anybody else?
13:18
i’m in the same boat mastermonkey but with lower stats. i hope i hear back by mid march
CheeseIsMyLoveLanguage
13:24
@mastermonkey45: Looking at some of the recent decisions in relation to when they went complete, I'd say it's a good sign. It seems many declines were sent within about 5-6 weeks of completion. Given those were applications that were SENT in January, I'd say that means you're still solidly in the running. :)
14:30
Sent an app to OSU in early december and have STILL not heard back
Give it 4 more weeks at least. Everyone in this chat needs to wait longer.
LSD+ is ad-free, with DMs, discounts, case briefs & more.