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- Advance_pricing_agreement abstract "An advance pricing agreement (APA) is an ahead-of-time agreement between a taxpayer and a tax authority on an appropriate transfer pricing methodology (TPM) for a set of transactions at issue over a fixed period of time (called \"Covered Transactions\"). Most APAs involve U.S. taxpayers and the US Internal Revenue Service (IRS), but APAs are also made outside the United States.Bilateral and multilateral APAsAPAs are generally bi- or multilateral—i.e. they also include agreements between the taxpayer and one or more foreign tax administrations under the authority of the mutual agreement procedure (MAP) specified in income tax treaties. The taxpayer benefits from such agreements since they are assured that income associated with covered transactions is not subject to double taxation by the IRS and the relevant foreign tax authorities. It is IRS policy to \"encourage\" taxpayers to seek bilateral or multilateral APAs where competent-authority provisions exist. Unilateral APAsIt is possible, however, that a taxpayer may negotiate a unilateral APA involving only the taxpayer and the IRS. In this case, the two parties negotiate an appropriate TPM for U.S. tax purposes only. Should the taxpayer be involved in a dispute with a foreign tax administration regarding the covered transactions, they may seek relief by requesting that the U.S. competent authority initiate a mutual agreement proceeding. This assumes, of course, that there is an applicable income tax treaty in force with the foreign country.The APA ProgramEach APA is handled by an APA team. One of the APA Program's designated team leaders is responsible for assembling the team, and it will generally consist of an economist, an international examiner, a LMSB field counsel, and—in bi- or multilateral cases—a U.S. competent-authority analyst tasked with leading discussions with treaty partners. Other team members may include an LMSB International Technical Advisor, LMSB exam personnel, or an Appeals Officer.".
- Advance_pricing_agreement wikiPageExternalLink APA.html.
- Advance_pricing_agreement wikiPageExternalLink apa_study_guide.pdf.
- Advance_pricing_agreement wikiPageID "10326808".
- Advance_pricing_agreement wikiPageLength "2814".
- Advance_pricing_agreement wikiPageOutDegree "6".
- Advance_pricing_agreement wikiPageRevisionID "693433933".
- Advance_pricing_agreement wikiPageWikiLink Category:International_taxation.
- Advance_pricing_agreement wikiPageWikiLink Category:Taxation_in_the_United_States.
- Advance_pricing_agreement wikiPageWikiLink Double_taxation.
- Advance_pricing_agreement wikiPageWikiLink Internal_Revenue_Service.
- Advance_pricing_agreement wikiPageWikiLink Tax_treaty.
- Advance_pricing_agreement wikiPageWikiLink Transfer_pricing.
- Advance_pricing_agreement wikiPageWikiLinkText "Advance pricing agreement".
- Advance_pricing_agreement wikiPageUsesTemplate Template:Refimprove.
- Advance_pricing_agreement wikiPageUsesTemplate Template:Reflist.
- Advance_pricing_agreement subject Category:International_taxation.
- Advance_pricing_agreement subject Category:Taxation_in_the_United_States.
- Advance_pricing_agreement hypernym Agreement.
- Advance_pricing_agreement type Organisation.
- Advance_pricing_agreement type Redirect.
- Advance_pricing_agreement comment "An advance pricing agreement (APA) is an ahead-of-time agreement between a taxpayer and a tax authority on an appropriate transfer pricing methodology (TPM) for a set of transactions at issue over a fixed period of time (called \"Covered Transactions\"). Most APAs involve U.S. taxpayers and the US Internal Revenue Service (IRS), but APAs are also made outside the United States.Bilateral and multilateral APAsAPAs are generally bi- or multilateral—i.e.".
- Advance_pricing_agreement label "Advance pricing agreement".
- Advance_pricing_agreement sameAs Q379209.
- Advance_pricing_agreement sameAs Advance_Pricing_Agreement.
- Advance_pricing_agreement sameAs m.02q8lpj.
- Advance_pricing_agreement sameAs Q379209.
- Advance_pricing_agreement wasDerivedFrom Advance_pricing_agreement?oldid=693433933.
- Advance_pricing_agreement isPrimaryTopicOf Advance_pricing_agreement.