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  • When is an APA appropriate?

    If you have cross-border dealings and you need assurance that those dealings comply with the arm’s length principle, you may seek an APA if the dealings are between:

    • related or unrelated separate legal entities (including permanent establishments of separate legal entities)
    • a permanent establishment and its head office
    • two permanent establishments of the same entity.
      Last modified: 15 Dec 2021QC 43088