In the current environment, taxpayers may be reluctant about continuing or initiating new APA applications. This is understandable given the significant level of economic uncertainty that many businesses face, uncertainty that for some taxpayers may mean it is not feasible to reach agreements on future APAs today. However, it is important to acknowledge the role of APAs in securing tax certainty for taxpayers and tax administrations, and in preventing future tax disputes.
OECD COVID-19 TPG paragraph 108
Category: TPG2020 Guidance on the transfer pricing implications of the COVID-19 | Tag: Advance pricing arrangement (APA), COVID-19
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