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Advance pricing agreement / arrangement |
A formal, negotiated agreement between an enterprise and one or more tax authorities confirming, in advance, the transfer pricing methodology to be applied to one or more specific intercompany transactions for a specified term.
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Advance compliance program |
A program designed to allow taxpayers and tax authorities to ensure the taxpayer is in compliance with relevant tax laws before any tax returns are filed, lessening the chance of a tax authority challenge on audit.
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Arm's length transfer price |
The transfer price that would be set for a related-party transaction if the parties to the transaction were not related (that is, dealing with each other at arm's length).
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Bilateral APA |
An APA entered into between the taxpayer and the tax authorities of two countries.
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Competent authority |
The representative of a government (often the tax authority) that is authorized to assist taxpayers in cases of double taxation that is not in accordance with the terms of a tax treaty (and, in many cases, the authority responsible for negotiating bi- and multilateral APAs).
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Contemporaneous documentation |
Documentation prepared in advance or at the time of a transaction, which verifies that reasonable efforts were made to establish arm's length prices (a statutory requirement in many jurisdictions).
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Fast-Track APA process |
A simplified, streamlined process designed to speed the completion of APAs for relatively simple and lower-risk intercompany transactions or dealings.
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Multilateral APA |
An APA entered into between the taxpayer and the tax authorities of more than two countries.
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Mutual Agreement Procedure |
A procedure set out in many tax treaties that allows designated government representatives of the treaty partners ("competent authorities") to work together to resolve international tax disputes, including cases of double taxation.
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Rollback |
The application of the terms of an APA to years before the APA commences.
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Transfer price |
The price at which related parties trade services, tangible property, and intangible property across international borders.
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Transfer pricing adjustment |
An adjustment that a tax authority makes to a company's taxable profits on audit if it disagrees with the arm's length price used by the company in its dealings with a related party in a foreign jurisdiction.
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Transfer pricing methodology |
The basis or formula used to establishing an arm's length transfer price or allocation; the particular methodology would be a central element to be negotiated in any APA.
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Unilateral APA |
An APA entered into between the taxpayer and one tax authority.
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