International Tax

Transfer Pricing: Competent Authority Consideration (Portfolio 6928)

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-1-
Brian Gleicher
White & Case
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