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CMS Tax Connect

January 2009 - Tax & Private Client. Legal Developments by CMS Group.

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An APA allows a group to confirm with the tax authorities that the prices used for intragroup transactions comply with the arm's length principle: to the extent the terms of the APA are complied with by the taxpayer, the tax authorities cannot reassess the prices used for the intragroup transactions covered by the APA. In other words, this procedure allows a taxpayer to obtain, a priori, tax certainty as regards its transfer pricing policy.


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