It’s a delight to note that the APA club is slowly expanding as the Third Amendment to the Tax Administration Regulation granted the Maldives Inland Revenue Authority (MIRA) the right to enter into APAs with taxpayers or other tax administrations with the purpose of providing certainty and clarity in the domain of transfer pricing. The Advance Pricing Regulation was published by the MIRA on 16 March 2021 stipulating the procedures to be followed for entering into an APA with the MIRA. The Regulation provides for unilateral, bilateral or multilateral APAs. MIRA may enter into an APA for a maximum period of 5 years. APAs can be applied by tax residents as well as PEs established in the Maldives entering into international transactions or arrangements with related parties.
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See AllMany thanks to Taxsutra for publishing my article. Amount A is a complex set of rules and may not yield enough revenues for the developing countries. Most importantly, adoption of Amount A MLC will ta
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