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Jun. 4--If you run a business and have not heard of APA yet, it's time to brush up before it's too late. APA stands for the "advance pricing arrangement", which is a method that allows a taxpayer to negotiate with the Revenue Department in advance to adopt an agreed price for an intra-company transaction. The method can help to avoid unnecessary disputes with tax authorities over transfer pricing.
The Revenue Department issued Departmental Regulation No. Por. 113/2545 on May 16 this year to regulate transfer pricing. The regulation came into force after the department invited a few tax specialists to attend the first public hearing it had ever held.
Transfer-pricing regulations are intended to prevent the manipulation of profits and losses within a group of related companies. For example, instead of selling products ...