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An advance pricing agreement (APA) is an ahead of time agreement between a taxpayer and a taxing authority on an appropriate transfer pricing methodology (TPM) for some set of transactions at issue over a fixed period of time〔OECD Transfer Pricing Guidelines – 2009〕 (called "Covered Transactions"). Most APAs involve US taxpayers and the US Internal Revenue Service (IRS), but APAs are also made outside the United States.〔(Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) ), Retrieved November 17, 2013〕 Bilateral and multilateral APAs APAs are generally bi- or multilateral—i.e., they also include agreements between the taxpayer and one or more foreign tax administrations under the authority of the mutual agreement procedure (MAP) specified in income tax treaties.〔(INTM422030 - Transfer pricing: methodologies: Advance Pricing Agreements: types of agreement ), Retrieved November 17, 2013〕 The taxpayer benefits from such agreements since it is assured that income associated with Covered Transactions is not subject to double taxation by the IRS and the relevant foreign tax authorities. It is IRS policy to "encourage" taxpayers to seek bilateral or multilateral APAs where competent authority provisions exist. Unilateral APAs It's possible, however, that a taxpayer may negotiate a unilateral APA involving only the taxpayer and the IRS. In this case, the two parties negotiate an appropriate TPM for U.S. tax purposes only. Should the taxpayer be involved in a dispute with a foreign tax administration regarding the Covered Transactions, the taxpayer may seek relief by requesting that the U.S. Competent Authority initiate a mutual agreement proceeding. This assumes, of course, that there is an applicable income tax treaty in force with the foreign country. The APA Program Each APA is handled by an APA team. One of the APA Program's designated team leaders is responsible for assembling the team, and it will generally consist of an economist, an international examiner, LMSB field counsel, and—in a bi- or multilateral case—a U.S. Competent Authority analyst tasked with leading discussions with treaty partners. Other team members may include an LMSB International Technical Advisor, LMSB exam personnel, or an Appeals Officer. ==References== 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「Advance pricing agreement」の詳細全文を読む スポンサード リンク
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