International transfer pricing: Advance pricing arrangements (APAs)

IC 94-4 "International Transfer Pricing: Advance Pricing Agreements (APA)

In Canada, paragraph 6 of the IC 94-4R International Transfer Pricing: Advance Pricing Arrangements (APAs)

IC94-4R, International Transfer Pricing: Advance Pricing Arrangements (APAs), 16 March 2001

Transfer pricing matters are instead referred to the Transfer Pricing Review Committee.

The IMPRESA transfer price concept will be replaced by a transparent form of organization without transfer prices.

The IMPRESA transfer price concept will be replaced by a transparent form of organization without transfer prices.

Calculation of transfer prices and their documentation

The examination and documentation of international transfer prices.

Particular documentation relating to transfer prices in Spain

Transfer price of raw materials

the identification of the method used for determination of the transfer pricing or the transfer price itself in the case of an advance pricing arrangement

(i) the identification of the method used for determination of the transfer pricing or the transfer price itself in the case of an advance pricing arrangement;

the identification of the method used for determination of the transfer pricing or the transfer price itself in the case of an advance pricing arrangement;

(h) the description of the set of criteria used for the determination of the transfer pricing or the transfer price itself in the case of an advance pricing arrangement;