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Can anyone provide some examples of critical assumptions to be incorporated in an advance pricing agreement (APA)?

Transfer Pricing
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Michael Kalson, PhD
An APA must contain specific stipulations that the chosen methodology for determining arm’s length prices rests on critical assumptions about the economic environment the enterprise operates in. There can be changes in the market arising from new technology, government regulations, or the nature of the functions and risks of the enterprises involved in the transactions that can undermine the ability of the chosen methodology for determining arm’s length pricing.
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