ABSTRACT

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Transfer Pricing Disputes: The European Commission Proposes Guidelines

Author: Nicolas MESSAGE

Type: Article : News

ref: 22007286-291

N0:2 of 2007

Pages: 286-291

The EU Commission has adopted, on February 26, 2007, a communication based on the work carried out by the EU Joint Transfer Pricing Forum. The Commission has drafted guidelines for Advance Transfer Pricing Agreements (APAs) which will make it easier for companies to avoid some of the problems caused by different transfer pricing rules in Member States. Transfer pricing rules aim at ensuring that in EU cross-border situations related companies allocate the correct tax base to the countries where they trade. The guidelines describe how Member States should conduct the APA procedure and provide guidance for taxpayers involved in the process. Following them will result in a quicker and more efficient agreement of the APA and in turn should encourage the use of APAs in the EU.