International Tax
Transfer Pricing: Competent Authority Consideration (Portfolio 6928)
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Description
This Portfolio also examines the costs and benefits of seeking a competent authority agreement.
Table of Contents
I. Introduction
II. Treaty Basis for Competent Authority Relief
III. U.S. Implementation of the Competent Authority Procedure
IV. Procedures for Requesting Competent Authority Assistance
V. Limitations on Applicability and Availability of Competent Authority Relief
VI. Considerations in Requesting Competent Authority Assistance
VII. Negotiation of the Agreement Between the Competent Authorities
VIII. Competent Authority Process in U.S.-Initiated Transfer Pricing Cases
IX. Competent Authority Process in Foreign-Initiated Transfer Pricing Cases
X. Finalization of Competent Authority Agreement
XI. Direct Costs and Benefits of a Competent Authority Agreement
XII. Indirect Costs and Benefits of a Competent Authority Agreement

Brian Gleicher
Partner
White & Case LLP
Partner
White & Case LLP