Common Contracts
1 similar Advance Pricing Agreement (Apa) contracts
ADVANCE PRICING AGREEMENT (APA) DI INDONESIAAdvance Pricing Agreement (Apa) • January 21st, 2005
Abstract: Transfer pricing is a common term used in referring to the problem of allo- cation of profits among compnaies in one group. In taxation, it is important to allocate profits between companies within the group as based on the norms of international taxation, a country takes taxes from its non- residents only for the profits obtained by the country. A country can take the profits of the total group and then allocate them to the source countries regardless of the price or nature of the transaction in the group. National approaches to transfer pricing means that the two tax authorities may have different views on fair price. Traditionally, a Mutual Agreement Procedure (“MAP”) settles settlement mechanism between the two tax authorities. However, there are some problems faced by taxpayers associated with the joint approval procedures. These problems will be solved by using the advanced pricing agreement (APA).
