Advance Pricing Agreements and Double Taxation – Key Concepts in the Context of Transfer Pricing

Ignat (Neacsu) Ioana ()
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Ignat (Neacsu) Ioana: The Bucharest University of Economic Studies

Ovidius University Annals, Economic Sciences Series, 2017, vol. XVII, issue 2, 565-570

Abstract: The paper presents the main advantages and disadvantages of an advance pricing agreement (APA), illustrates a practical example regarding a situation of double taxation of results and presents a comparative analysis between the number of advance pricing agreements granted by the EU countries and the number of Double Tax Treaties concluded by these countries. Results show that an APA presents more advantages than a transfer pricing file, but its disadvantages (regarding the cost and the period of time needed for the issuance) have a big impact on the business of a company and determine most of the taxpayers to choose a transfer pricing documentation file rather than to apply for an APPA. The results of this research also show that countries which have concluded a big number of Double Tax Treaties tends to grant much more APAs compared with the other category of countries where the number of Double Tax Treaties is smaller.

Keywords: transfer pricing; advance pricing agreements; double taxation; tax treaties (search for similar items in EconPapers)
JEL-codes: K34 M40 (search for similar items in EconPapers)
Date: 2017
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Persistent link: https://EconPapers.repec.org/RePEc:ovi:oviste:v:xvii:y:2017:i:2:p:565-570

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