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09
9 月

Advance Pricing Agreement Scheme

Rule 10(F)(a) defines the term “agreement” as a prior acidification agreement between the board of directors and the applicant, with the agreement of the central government in accordance with section 92CC (1), which provides that the board of directors may enter into an ex ante price agreement with any person, with the agreement of the central government. determine the subcontracting price or determine how the subcontracting price is to be determined in relation to the international transaction to be carried out by that person. APAs offer you the opportunity to enter into an agreement with us on the future application of the arm`s length principle to your transactions with international related parties. The transfer pricing officer shall carry out the compliance check of the agreement for each of the years covered by the agreement. It may require the assessment to demonstrate compliance, including compliance with critical assumptions, the accuracy of the takeover date or information and the consistency of the application of the transfer pricing methodology. The evaluator must provide any information or document attesting that the terms of the agreement have been met. Jurisdiction of the BZSt in mutual agreement procedures, arbitration and APAs Upon receipt of the request, the BZSt verifies that all conditions (including the applicant`s agreement not to contest the fees) are met for the implementation of an aPA procedure. An APA procedure shall only be implemented if the request is admissible and reasoned. Anyone who has entered into a consultation prior to filing, if they wish to enter into an agreement, can be set up in the application number. If you have done so, we are administratively bound by the terms of the APA and we do not collect any additional income tax payable based on the prices set under the APA for covered cross-border transactions. The Advance Pricing Arrangement (APA) program is an important part of our compliance assurance strategy. The terms of the agreement may include, inter alia, that an Advance Pricing Agreement (APA) is a prior agreement between a taxable person and a tax department on an appropriate transfer pricing method (TPM) for a number of transactions under negotiation[1] (“Covered Transactions”).

The application for renewal of an agreement may be submitted in the form of a new application for approval, the procedure described in this Article being the same as that described in this Article, with the exception of the pre-submission consultation procedure. The applicant shall determine the content of the PA in his application. The application must define the scope of application, both in time and in substance. In addition, mention should be made of other countries that require advance pricing reporting. When an applicant requests a multilateral ABS (with more than two participating states), the PA consists of several bilateral ABS. The binding effect of the agreement shall lapse only if a party informs the parties concerned or the parties concerned. . . .

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