Advance Pricing Arrangement is an arrangement between MIRA and taxpayer and in some cases, associates of taxpayers regarding the appropriate transfer pricing methodology for a set of transactions, to mitigate transfer pricing related issues.
Advance Pricing Arrangements entered in to will prevail over any other provision in any tax law which stipulates any rule with regard to transactions with associates. Transfer prices agreed in the APA would be the arm’s length price prescribed for such transactions under the Income Tax Act.
The following conditions are required to be met in order to apply for an APA arrangement
The APA process and further information will be available in Advance Pricing Regulation and APA Guide
To apply for Advance Pricing Arrangements, “Request for Pre-filing Consultation” (MIRA 921) form together with supporting documents shall be submitted to [email protected].