Advanced Pricing Agreement definition

Advanced Pricing Agreement means the proposed transfer pricing agreement among, Seller, Maquiladora, the United States Internal Revenue Service and certain Mexican Tax authorities for transactions between Seller and Maquiladora for the annual tax periods of Maquiladora commencing January 1, 2000 through January 1, 2004, which has been submitted to the United States Internal Revenue Service and the appropriate Mexican Tax authorities.
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Examples of Advanced Pricing Agreement in a sentence

  • All pre-test mean scores were at the low end of the mild range: Depression subscale (mild range = 10 – 13) (m = 10.24); Anxiety subscale (mild range = 8 – 9) (m = 8.16); Stress subscale (mild range = 15 – 18) (m = 15.04).

  • The appellant entered into an Advanced Pricing Agreement with the CBDT5 under Section 92 CC of the Act.

  • In relation to royalties received from the USA a bilateral Advanced Pricing Agreement (APA) has been entered into with both the Australian Tax Office (ATO) and the United States Internal Revenue Service (US IRS) covering the period 1 July 2005 to 30 June 2010.

  • Consideration should be given for legislating the Advanced Pricing Agreement (APA) process.

  • Evaluation of Advanced Pricing Agreement ProceduresIn the future, the ALAS states and staff could also explore the feasibility and desirability of developing and using an advance pricing agreement process with taxpayers.

  • Advanced Pricing Agreement Program Training on Cost Sharing Buy-In Payments.

  • Sanctions for breach of an obligation are reduced in cases where the taxpayer requests for an Advanced Pricing Agreement or pays its outstanding taxes without appeal.

  • In its annual accounts EDP Finance BV explains this difference by "an Advanced Pricing Agreement settled with the Dutch tax authorities, which establishes the taxable turnover under certain assumptions and requirements”.40 However, according to Dutch law, an APA determining a ´transfer pricing´ method that is beneficial for the company can keep the spread (i.e. the profit that is allocated to the jurisdiction) low in the Netherlands, but not reduce the income tax rate paid on those profits.

  • Core tax adjustments for discrete tax items totaled $40 million, primarily related to the recognition of an Advanced Pricing Agreement between US and Switzerland tax authorities for fiscal years 2019 through 2021.

  • MOF has issued revisions of PMK240/2015 and PMK7/2015 as well as used Minister of Finance Regulation 234/2015 and DGT Decree 36/2017 in order to implement dispute resolution mechanisms (BEPS Action 14): In particular, the Borrower has: (a) implemented Advanced Pricing Agreement (APA) and Mutual Agreement Procedure (MAP) dispute resolution mechanisms; and (b) created a sub-directorate dedicated to enable Indonesia to manage international tax disputes.

Related to Advanced Pricing Agreement

  • Pricing Agreement means the pricing agreement between the Trust, the Debenture Issuer, and the underwriters designated by the Regular Trustees with respect to the offer and sale of the Preferred Securities.

  • Back-Up Servicing Agreement means that certain Back-Up Servicing Agreement to be entered into by and among the Company, the Administrative Agent and the Back-Up Servicer, as such agreement may be amended, restated, supplemented or otherwise modified from time to time.

  • Master Servicing Agreement means the master servicing agreement entered into on 20 May 2013 between the Guarantor, the Issuer and the Master Servicer.

  • Advance Purchase Agreements means (a) an advance or deferred purchase agreement if the agreement is in respect of the supply of assets or services and payment in the normal course of business with credit periods which are normal for the relevant type of project contracts, or (b) any other trade credit incurred in the ordinary course of business.

  • Non-Lead Securitization Servicing Agreement shall have the meaning assigned to such term in Section 2(b).

  • Lead Securitization Servicing Agreement means (i) the pooling and servicing agreement or other comparable agreement related to the Lead Securitization, and (ii) on and after the date on which the Mortgage Loan is no longer subject to the provisions of the Lead Securitization Servicing Agreement, the “Lead Securitization Servicing Agreement” shall be determined in accordance with the second paragraph of Section 2(a).

  • Subservicing Agreement The written contract between the Master Servicer and any Subservicer relating to servicing and administration of certain Mortgage Loans as provided in Section 3.02, generally in the form of the servicer contract referred to or contained in the Program Guide or in such other form as has been approved by the Master Servicer and the Depositor.

  • Securitization Servicing Agreement means the Lead Securitization Servicing Agreement or any Non-Lead Securitization Servicing Agreement.

  • Mortgage Loan Purchase Agreement The agreement between the Seller and the Depositor, regarding the transfer of the Mortgage Loans by the Seller to or at the direction of the Depositor, substantially in the form of Exhibit D annexed hereto.

  • Loan Purchase Agreement The Loan Purchase Agreement described in the Recitals to this Agreement, which Loan Purchase Agreement incorporates the terms of the Aurora Loan Services Seller Guide, as the same may be amended from time to time.

  • Sub-Servicing Agreement The written contract between the Servicer and a Sub-Servicer relating to servicing and administration of certain Mortgage Loans as provided in Section 3.02.

  • Sale and Servicing Agreement means the Sale and Servicing Agreement, dated as of the Closing Date, between the Seller, the Issuer, the Servicer and the Indenture Trustee, as the same may be amended, modified or supplemented from time to time.

  • Primary Servicing Agreement means the agreement between the applicable Primary Servicer and the Master Servicer, under which such applicable Primary Servicer services the Mortgage Loans set forth on the schedule attached thereto.

  • Pricing Side Letter means that certain letter agreement between Buyer and Seller, dated as of the date hereof, as the same may be amended, restated, supplemented or otherwise modified from time to time.

  • Other Servicing Agreements The Servicing Agreements other than the WFHM Servicing Agreement.

  • Loan Modification Agreement means a Loan Modification Agreement in form and substance reasonably satisfactory to the Administrative Agent and the Borrower, among the Borrower, the other Loan Parties, one or more Accepting Lenders and the Administrative Agent.

  • Mortgage Loan Agreement means the Loan Agreement, dated as of February 14, 2020, between the Borrower, as borrowers, and the Original Lenders, as lender, as the same may be further amended, restated, supplemented or otherwise modified from time to time, subject to the terms hereof.

  • Underlying Loan Agreement means, with respect to any Loan, the document or documents evidencing the commercial loan agreement or facility pursuant to which such Loan is made.

  • Backup Servicing Agreement means the Amended and Restated Backup Servicing Agreement dated as of the Closing Date among the Borrower, the Servicer, the Administrative Agent and the Backup Servicer, as amended by that certain Amendment No. 1 to Backup Servicing Agreement dated as of April 14, 2009, as the same may from time to time be further amended, restated, supplemented, waived or modified.

  • Servicing Arrangement is defined in Section 11.06(b).

  • Non-Lead Servicing Agreement means the pooling and servicing agreement, trust and servicing agreement or other similar agreement to be entered into in connection with a Non-Lead Securitization Note.

  • Interim Servicing Agreement The agreement to be entered into by the Purchaser and the Interim Servicer, providing for the Interim Servicer to service the Mortgage Loans as specified by the Interim Servicing Agreement.