Advance pricing arrangement (“APA”)
An arrangement that determines, in advance of controlled transactions,
an appropriate set of criteria

Episode 4

The international standard that OECD member countries have agreed
should be used for determining transfer prices for tax purposes. It is set forth
in Article 9 of the OECD Model Tax Convention as follows: where
“conditions are made or imposed between the two enterprises in their
commercial or financial relations which differ from those which would be
made between independent enterprises, then any profits which would, but
for those conditions, have accrued to one of the enterprises, but, by reason of
those conditions, have not so accrued, may be included in the profits of that
enterprise and taxed accordingly”.