Advanced Pricing Arrangement / Agreement

In terms of the Transfer Pricing Rules, an Advance Pricing agreement is an agreement entered into between the Competent Authority and a relevant foreign Competent Authority under the provisions for a Mutual Agreement Procedure found in the applicable treaty/convention which agreement determines in advance of cross-border arrangements between associated enterprises, an appropriate set of criteria for the determination of the transfer pricing for those permanent establishment in line with the arm's length standard as developed through international tax standards.

For further information on the submission an Advance Pricing Arrangement/Agreement, one may wish to refer to the Transfer Pricing Rules that were issued.