Pengertian Dari Price Agreement
The above problems cannot be resolved simply by appropriate coping mechanisms in accordance with Article 9, paragraph 2, or by a Mutual Agreement Procedure (MAP) in accordance with Article 25 of the OECD Model Standard Convention (OECD model). In addition to ensuring legal certainty and a simple tax calculation, the benefits of the APA must no longer be corrected when considering the selling price and profit of products sold by taxpayers to companies in the same group. The APA may be unilateral, i.e. an agreement between the Director General of Taxes and taxpayers or bilaterally, i.e. the agreement between the Director General of Taxes and the tax authorities of other countries regarding taxpayers who are on their territory. In principle, the bilateral and multilateral APA was developed from Article 25 of the OECD model. This is based on Article 25, paragraph 3 of the OECD model, which states that tax authorities can resolve disputes because of differences in OECD interpretation or application through POPs, and one country`s tax administration can discuss with tax authorities in other countries efforts to avoid double taxation in cases that are not specifically regulated by the OECD model. The price agreement consists of 2 words, namely the price and the agreement As the name suggests, the agreement, this agreement is made before the entry into force of the fiscal year or the transaction. In order to determine, against existing transactions, the amount of the price to be reported to the tax office. If agreed, the agreement will be binding on the tax authorities and taxpayers. In addition to the `price agreement`, you can also look for an explanation for the following words: The pros and cons of the pre-price agreement (APA) required by the OECD guidelines for 2010 are to be seen below: the benefits of the pre-price agreement (APA), in addition to guaranteeing legal security and a simple tax calculation, must be reviewed by the Treasury when considering the selling price and profits of products that taxpayers do not sell to companies in the same group. The most important thing in the definition of the APA above is that the APA does not regulate the issue of pricing, as the APA is only an agreement on the application of the transfer pricing method under acceptable conditions (Burns, 2003).
With the ease of resolving transfer pricing conflicts by appropriate adjustment and MAP, then developed another billing system called Advance Pricing Agreement (APA). The third type, the multilateral APA, is the authorization of subjects to two or more tax administrations. This guy`s very common right now. The main difference between unilateral, bilateral and multilateral types is the number of taxpayers and tax authorities participating in the Apa. The following is a translation of the importance of the price agreement in Indonesian Indonesian in the English-Indonesian dictionary The approach to the price agreement used at the time was to in the event that the subject believes that the transfer pricing agreement may lead to the imposition of several taxes, taxpayers can file a written application with the Director General of Taxes for the implementation of a Mutual Agreement Procedure (MAP) with the state tax authorities/jurisdiction of P3B`s partners.