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CMS Tax Connect


An APA allows a group to confirm with the tax authorities that the prices used for intragroup transactions comply with the arm's length principle: to the extent the terms of the APA are complied with by the taxpayer, the tax authorities cannot reassess the prices used for the intragroup transactions covered by the APA. In other words, this procedure allows a taxpayer to obtain, a priori, tax certainty as regards its transfer pricing policy. As shown in the attached country specific developments, many European countries have introduced an APA procedure into their legislation since the late 1990s.

CMS Tax Connect_072008_ENG
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