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

See all articles by Markus Brem

Markus Brem

GTP GlobalTransferPricing Business Solutions GmbH; University of Augsburg

Abstract

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

Brem, Markus, 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, Available at SSRN: https://ssrn.com/abstract=874912

Markus Brem (Contact Author)

GTP GlobalTransferPricing Business Solutions GmbH ( email )

Wertinger Straße 40
86368 Gersthofen (Augsburg)
Germany
+49 (821) 9089979 - 0 (Phone)
+49 (821) 9089979 - 89 (Fax)

HOME PAGE: http://www.GlobalTransferPricing.com

University of Augsburg ( email )

Universitätsstr. 2
Augsburg, 86159
Germany

HOME PAGE: http://https://www.uni-augsburg.de/de/fakultaet/wiwi/prof/bwl/schultze/team/markus-brem/

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