Editing Transfer pricing (section)

==Agreements between taxpayers and governments and dispute resolution==
Tax authorities of most major countries have entered into unilateral or multilateral agreements between taxpayers and other governments regarding the setting or testing of related party prices.  These agreements are referred to as '''advance pricing agreements''' or '''advance pricing arrangements''' (APAs).  Under an APA, the taxpayer and one or more governments agree on the methodology used to test prices.  APAs are generally based on transfer pricing documentation prepared by the taxpayer and presented to the government(s).  Multilateral agreements require negotiations between the governments, conducted through their designated '''competent authority''' groups.  The agreements are generally for some period of years, and may have retroactive effect.  Most such agreements are not subject to public disclosure rules.  Rules controlling how and when a taxpayer or tax authority may commence APA proceedings vary by jurisdiction.<ref>See OECD Guidelines 4.124 ''et seq''.; U.S. IRS [https://www.irs.gov/pub/irs-apa/rp-08-31.pdf Rev. Proc. 2008-31]; China Circular 2 Art. 46 ''et seq''.</ref>