Agreements Between Taxpayers and Governments and Dispute Resolution
Tax authorities of most major countries have entered into unilateral or multilateral agreements between taxpayers and other governments regarding the setting or testing of related party prices. These agreements are referred to as advance pricing agreements or advance pricing arrangements (APAs). Under an APA, the taxpayer and one or more governments agree on the methodology used to test prices. APAs are generally based on transfer pricing documentation prepared by the taxpayer and presented to the government(s). Multilateral agreements require negotiations between the governments, conducted through their designated competent authority groups. The agreements are generally for some period of years, and may have retroactive effect. Most such agreements are not subject to public disclosure rules. Rules controlling how and when a taxpayer or tax authority may commence APA proceedings vary by jurisdiction.
Read more about this topic: Transfer Pricing
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“The difference between de jure and de facto segregation is the difference open, forthright bigotry and the shamefaced kind that works through unwritten agreements between real estate dealers, school officials, and local politicians.”
—Shirley Chisholm (b. 1924)
“The Federal Constitution has stood the test of more than a hundred years in supplying the powers that have been needed to make the Central Government as strong as it ought to be, and with this movement toward uniform legislation and agreements between the States I do not see why the Constitution may not serve our people always.”
—William Howard Taft (1857–1930)
“And so the reliance on Property, including the reliance on governments which protect it, is the want of self-reliance.”
—Ralph Waldo Emerson (1803–1882)
“The king said, -Divide the living boy in two; then give half to the one, and half to the other. But the woman whose son was alive said to the king -because compassion for her son burned within her - -Please, my lord, give her the living boy; certainly do not kill him! The other said, -It shall be neither mine nor yours; divide it. Then the king responded: -Give the first woman the living boy; do not kill him. She is his mother.”
—Bible: Hebrew, 1 Kings. 3:25-37.
Solomon resolves a dispute between two women over a child. Solomon’s wisdom was proven by this story.
“Had I been less resolved to work, I would perhaps had made an effort to begin immediately. But since my resolution was formal and before twenty four hours, in the empty slots of the next day where everything fit so nicely because I was not yet there, it was better not to choose a night at which I was not well-disposed for a debut to which the following days proved, alas, no more propitious.... Unfortunately, the following day was not the exterior and vast day which I had feverishly awaited.”
—Marcel Proust (1871–1922)