What is rollback provision?

Rollback provisions essentially mean that a negotiated position on pricing of an international transaction reached under the advance pricing arrangement can be applied to a similar transaction for up to 4 (four) years in the past.

What is rollback in income tax?

The “roll back” provisions refers to the applicability of the methodology of determination of ALP, or the ALP, to be applied to the international transactions which had already been entered into in a period prior to the period covered under an APA.

What is APA in transfer pricing?

What is an Advance Pricing Agreement (APA)? An APA is an agreement between a tax payer and tax authority determining the transfer pricing methodology for pricing the tax payer’s international transactions for future years.

What is the meaning of advance pricing agreement?

An advance pricing agreement (APA) is an ahead-of-time agreement between a taxpayer and a tax authority on an appropriate transfer pricing methodology (TPM) for a set of transactions at issue over a fixed period of time (called “Covered Transactions”).

What are transfer pricing methods?

Another traditional transaction method for determining transfer pricing is the resale price method. This method starts by looking at the resale price of a product that has been bought from an associated enterprise and then sold onto an independent party. This gross resale price margin is deducted from the resale price.

What is the main purpose of the APA?

The stated mission of APA is to advance the creation, communication and application of psychological knowledge to benefit society and improve people’s lives.

What is APA style example?

APA in-text citation style uses the author’s last name and the year of publication, for example: (Field, 2005). For direct quotations, include the page number as well, for example: (Field, 2005, p. 14).