Though they are relatively new in Hungary, advance pricing arrangements (APA) are now quite popular among multinational companies. APAs can be obtained relatively quickly and cost efficiently, in close cooperation with a special team of tax authority professionals. Zoltán Lipták of Ernst & Young says the APA team of the tax authority has a track record of being flexible and cooperative with taxpayers.
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The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, and rejects protection for indirect transfers and tightening conditions for Mauritius‑based investors claiming DTAA relief
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Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said