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CAMBIO Avocat can help you negotiate Advance Pricing Arrangement (APA)
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CAMBIO Avocat helps you prepare the file that will be sent to the French competent authorities in order to obtain an Advance Pricing Arrangement (APA).
CAMBIO Avocat also assists you in negotiating the Advance Pricing Arrangement with the competent tax authorities
Preparation of the APA application is invoiced on a lump-sum basis, which gives you a clear idea of the cost of my support.
Support in negotiating an APA with the competent authorities is billed on a time-spent basis, at an hourly rate that I communicate to you in advance. I also provide you with an estimate of the fees, which is adjusted according to the actual time spent.
Frequently asked questions
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The Advance Pricing Agreement (APA) is a tax ruling that offers a degree of security. It enables a company to obtain agreement from the competent authorities on the transfer pricing policy it applies.
The APA protects the company against any challenge by the tax authorities to the transfer pricing policy for the years concerned, provided that the agreement is complied with.
The duration is set out in the Advance Pricing Arrangement (APA). It cannot be less than 3 years or more than 5 years.
The APA can be unilateral: this arrangement is negotiated between the company and the French competent authorities.
The APA can be bilateral or multilateral: this arrangement is negotiated between the company, the French competent authorities and one or more foreign competent authorities.
In the case of an agreement with a single foreign competent authority, this is referred to as a bilateral arrangement. If several foreign competent authorities are involved, it is referred to as a multilateral arrangement.
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