Advance Pricing Agreements: Shifts in International Tax Policies - How Global Business Processes Force Governance Change Regarding International Income Tax Base Allocation of Multinational Companies
GTP Series, Forthcoming
Posted: 15 Jan 2006
This analysis refers to the emergence of so-called Advance Pricing Agreements (APA) in international taxation and corresponding APA programs in individual countries. APAs are a type of non-bureaucratic, cooperative governance that exists between the multinational corporate taxpayer and the relevant tax administration; if an APA is bi-/multilateral, the negotiation is also between the tax authorities of the other sovereign tax jurisdictions involved. The analysis examines how globalizing business processes trigger governance change on the nation state level regarding the identification and allocation of the tax base of multinational companies. The introduction of APA programs and the generation of APAs are considered to be an example of such governance change.
By means of a political analysis, this thesis seeks to identify factors which might explain variation in the evolution of national APA programs and the implementation of individual APAs between the taxpayer and the tax authorities. Differences in institutions, economic conditions, and the actors involved are important in explaining variation across countries. As part of the analysis, this analysis offers a comprehensive literature overview and a case study on APAs in two countries, supporting the model on governance change in international taxation.
Keywords: Advance pricing agreement, international taxation, cooperation, non-bureaucratic, governance, transfer pricing
JEL Classification: F02, H11, H87, K34, L14
Suggested Citation: Suggested Citation