Multilateral advance pricing agreements - A multifaceted approach to a global conundrum?
Source: Australian Tax Forum Journal Article
Published Date: 1 Sep 2013
There is currently a revival of interest in multilateral advance pricing agreements (MAPAs), not only at the Organisation for Economic Cooperation and Development (OECD) level, but also among revenue authorities. The revenue authorities in the United States, Canada and the United Kingdom have recently demonstrated an interest in multilateral approaches to transfer pricing controversy resolution. This article examines this revived interest in MAPAs before going on to consider some past multilateral agreements, in order to gain valuable insights into the multilateral process going forward. The views of some of the main protagonists in these agreements are discussed, including reflections from the coordinator of the APA Programme in the UK until 2012, a competent authority negotiator in many of the world’s past MAPAs.
Current economic, fiscal and accounting developments have made transfer pricing a top priority concern for all multinational enterprises (MNEs), there has been an unprecedented rise in international collaboration between tax administrations, and MAPAs are the only transfer pricing controversy management tool to simultaneously offer multiple revenue authorities and MNEs prospective certainty. This article contributes to the study of tax law and policy in that it examines the advantages and disadvantages of prospective multiparty dispute resolution in this globally important area.
Sorry, this is subscriber only content.
To gain access to this material and much more - Subscribe Now.
(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).
Already a Subscriber? Login now
Already a Subscriber? Login now
Details
- Published By: Michelle Markham
- Published On:1 Sep 2013
The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
The Tax Institute
(ABN 45 008 392 372 (PRV14016))
("TTI")
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
Copyright Statement
All materials provided on this site are protected by copyright and are owned by or licensed to TTI.
Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.
Tags
Share this page