Advance Pricing Agreements and elimination of double taxation
Advanced Pricing Agreements (APAs) , Mutual Agreement Procedures and Arbitration Convention
The possibility of reaching Advance Pricing Agreements with the tax authorities for fixing a transfer pricing policy in a particular controlled transaction provides a greater degree of legal certainty to the companies.
Transfer Pricing advises and manages the entire negotiation process in Advance Price Agreements with the Spanish Revenue Agency, in order to obtain the approval of the agreement granting greater legal certainty to the client. In the same way, with the support of the professionals of our international network, our firm advises on negotiating such agreements with foreign tax authorities in bilateral or multilateral processes.
Elimination of Double Taxation
In case that a tax audit ends up with an adjustment of transfer prices of a taxpayer, a double taxation situation arises automatically if that state is not regularized (compensating adjustment) in the other related entity.
Transfer Pricing advises on possible forms of removal of double taxation, both at accounting and at tax level, based on the regulations of the jurisdictions involved as well as on the possible existing solutions in accordance with current legislation.
Our Firm assists taxpayers in resolving Mutual Agreement Procedures for the elimination of double taxation or MAPs and in the preparation of international arbitration conventions.
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David Canabate Partner - Madrid