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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: 27 Jul 2020QC 43088