Chapter Twenty-Four

Singapore Implements Advance Pricing Arrangement Procedure

The Inland Revenue Authority of Singapore (IRAS) implemented Singapore’s advance pricing arrangement (APA) procedure on October 20, 2008, through the issuance of a supplementary circular. This detailed APA procedure implements Section 6 of Singapore’s transfer pricing guidelines that the IRAS had issued on February 23, 2006. As a general matter, Singapore permits a Singapore taxpayer to undertake an APA in one of two forms:1

1. The taxpayer can enter into an APA that is a unilateral arrangement involving the taxpayer and the IRAS standing alone.
2. The taxpayer can enter into a bilateral agreement or a multilateral agreement that involves agreement between Singapore and one or more of its tax treaty partners.

Two specific APA facets of the Singapore APA procedure are particularly relevant to U.S. taxpayers:

1. The United States and Singapore do not have an income tax treaty (except for airlines). As such, the Singapore and the United States cannot form a bilateral APA. Nevertheless, such a taxpayer might choose to consider implementing a matched unilateral APA agreement.
2. The Singapore supplementary circular does not permit a taxpayer to enter into a roll back in the case of unilateral APAs.

OBJECTIVES OF THE SUPPLEMENTARY CIRCULAR

The IRAS issued the supplementary APA circular to achieve three specific objectives:2

1. To provide the taxpayer with the considerations and procedures that the taxpayer should observe as an APA applicant. This APA application process involves these two steps:
a. The filing of the APA application by the taxpayer and the acceptance by the IRAS of the APA application.
b. The discussion and agreement by or among the competent authorities concerned.
2. To address the circumstances under which the IRAS may allow an APA applicant’s request for the APA to “roll back” and apply to roll-back years.
3. To set out the circumstances that would warrant the IRAS from discontinuing the APA process that the taxpayer initiated.

WHAT THE SUPPLEMENTARY CIRCULAR PROVIDES

Singapore’s APA procedure, as specified in the supplementary circular, contains these parts:

  • Considerations for facilitating acceptance of the APA application by the IRAS and discussions of APA application with the taxpayer
    • Pre-filing of the APA application
    • Formal APA submission
    • APA review and negotiation
  • The APA roll back
  • Discontinuation of the APA process
    • Nonsubmission of the APA application after expiration of specified time frames
    • Insufficient level of support efforts during the APA process
    • Absence of communication as to complete information
  • Effective date
  • Inquiries

MINIMUM INFORMATION REQUIREMENTS

Singapore’s APA procedure specifies the minimum information the IRAS will accept for the pre-filing meeting and for submitting the formal APA application:

  • The taxpayer’s name, address, tax identification number, and contact details
  • The letter of authorization from the taxpayer to its tax advisors or other representatives the taxpayer engages for purposes of the APA application
  • A statement indicating whether the proposed APA application is a unilateral APA, a bilateral APA, or multilateral APA
  • The nature of the covered transaction, and how these transactions relate to the overall business activities of the enterprise involved
  • The covered transactions entities and detailed organized chart
  • The covered period, including any roll-back period
  • An overview of the next points by the covered entities during the proposed APA period:
    • Functions undertaken
    • Assets employed
    • Risks assumed
  • An analysis of how the functions the covered entities undertake, the assets the covered entities employ, and the risks the covered entities assume have changed. This comparison is based on the period prior to the commencement of the proposed APA.
  • The transfer pricing methodology chosen and the reasons why the taxpayer selected that transfer pricing method.
  • The transfer pricing analysis, including these items where applicable:
    • Taxpayer’s choice of the tested party
    • Profit level indicator
    • Screening criteria the taxpayer suggests for comparables and the database the taxpayer uses, as suggested at the pre-filing meeting
    • Transfer pricing adjustments the taxpayer may need, as suggested at the pre-filing meeting
    • Arm’s length result, as suggested at the pre-filing meeting
  • The critical assumptions under which the proposed APA will operate.

CONSIDERATIONS FOR ACCEPTING THE APA

The IRAS specifies that the APA process is a voluntary process and that the taxpayer must initiate the APA process for it to occur. In this regard, then, the Singapore APA initiation process is more akin to that of the U.S. APA process rather than that of the APA process in Australia. The initiation of the APA process in Singapore does not suspend any examination or enforcement process that the IRAS might conduct.3

The IRAS cautions that when initiating the APA process, the taxpayer would have recognized the advantages of seeking an APA with one or more competent authorities. The IRAS cautions regarding the advantages of seeking an APA with one or more competent authorities are curious in that a taxpayer might elect to have a unilateral APA—which does not directly involve competent authorities—rather than having bilateral APA or a multilateral APA. The IRAS suggests that it is in the interest of the taxpayer to take steps “to provide well for the APA process.”4

The IRAS warns that, while an APA provides many advantages, the taxpayer should not underestimate the obligations and effort on its part to see the APA process to its fruition. These efforts might prove a highly time-consuming and costly exercise not only to the taxpayer but also to competent authorities concerned.5

When embarking on an APA, the IRAS recommends that the taxpayer be ready to fully cooperate with the competent authorities concerned, doing so to support their consideration of the APA application. This cooperation requires, among other things, the taxpayer’s readiness to dedicate sufficient resources throughout the APA process to provide:6

  • Swift, accurate, and good-quality analysis of the issues that arise or might arise
  • Responses and clarifications to queries raised by competent authorities in the APA process

The taxpayer needs to dedicate resources to the APA process. In addition to having those dedicated resources, the taxpayer should “take appropriate active steps” beginning with the commencement of its APA preparation to maximize:

  • The acceptance of the APA application by the IRAS
  • Productive discussion and agreement by and/or among the competent authorities concerned

The IRAS observes, however, that a taxpayer that avails itself of the APA facility might not always appreciate the extent of the resources and efforts the taxpayer needs to effectuate this APA process.7

The supplementary circular states that it is critical that a taxpayer contemplating availing itself of the APA facility fully understand the obligations and efforts required on its part in this regard. Based on its experience in processing APA applications, particularly APA applications that involve agreement with another competent authority, the IRAS believes that, in such circumstances, the taxpayer should observe certain requisites and procedures to enhance the chances of a successful APA process. The supplementary circular explains the requisites and procedures the taxpayer should observe in order to support the APA process well.8

PRE-FILING APA PROCESS

The supplementary circular defines an APA as a determination, made in advance, of an appropriate set of criteria to ascertain the transfer prices of a specified period of time, the “proposed covered period.” The pre-filing APA process addresses both the timing of the APA process and duration of the APA. An example indicates that the IRAS will accept an APA having a five-year period. The IRAS suggests a six-month time frame in applying for the APA before the inception of the proposed covered period. This APA turnaround time is quite short compared with that of the United States and Australia. The supplementary circular contains an example in which the proposed APA covered period begins September 1, 2009, and ends August 31, 2014, suggesting that the taxpayer strive to submit the APA application no later than March 1, 2009.9

The IRAS suggests that the taxpayer contact the IRAS early in the submission of the APA application to initiate a pre-filing meeting. The purpose of the pre-filing meeting is to initiate a pre-filing meeting, before the pre-filing meeting between the taxpayer and the IRAS to discuss the proposed APA application.10 The IRAS recommends that the taxpayer’s first pre-filing meeting with the IRAS should preferably take place at least three months before the taxpayer intends to submit an APA application with the IRAS and/or another competent authority. This three-month delay is designed to allow sufficient time for:

  • The IRAS to consider information provided by the taxpayer relevant to the feasibility of the APA application
  • The IRAS to seek further details from the taxpayer relevant to the feasibility of the APA application
  • The taxpayer to prepare and respond to any additional information required

Returning to the example in which the proposed APA covered period begins September 1, 2009, and ends August 31, 2014, and the taxpayer would submit the APA application by March 1, 2009, the first taxpayer–IRAS pre-meeting should take place no later than December 1, 2008. It is not uncommon for taxpayers and the IRAS to have more than one pre-filing meeting. Because more than one meeting is likely, the taxpayer should provide adequate lead time for the first pre-filing meeting and for any subsequent pre-filing meetings, as appropriate. The taxpayer should take into account the potential complexities surrounding the transactions covered by the APA.

The taxpayer should provide certain minimum information to the IRAS to facilitate constructive discussion pertaining to the proposed APA during the first pre-filing meeting. The taxpayer should provide this information to the IRAS at least one month before the first pre-filing meeting.11 The minimum information requirements are discussed above.

The taxpayer and the IRAS intend that the purpose of the first pre-filing meeting is to address the material aspects of taxpayer’s proposed APA application face-to-face. Accordingly, the IRAS imposes a unique but obvious requirement: that the taxpayer’s representatives have good in-depth business knowledge and processes in relation to:12

  • APA covered transactions
  • Oversight responsibilities of the taxpayer’s tax matters to participate in the first pre-filing meeting
  • Any subsequent pre-filing meeting, upon request

It is usual for the tax professional to request its tax agent to attend pre-filing meetings with the taxpayer.

Three time periods precede the APA covered period:13

1. The taxpayer is to provide certain minimum information to the IRAS one month before the taxpayer and the IRAS have the pre-filing APA meeting.
2. The first pre-filing meeting between the taxpayer and the IRAS is to take place at least three months before the taxpayer intends to submit an APA application.
3. The taxpayer should submit the APA application six months before the proposed covered period is to begin.

A normal process during the pre-filing meeting is for the IRAS to request clarification or additional information from the taxpayer so that the IRAS can better assess the proposed APA application. During this pre-filing meeting, the IRAS will provide preliminary comments to the proposed APA application. These preliminary comments will include suggestions to the taxpayer (e.g., steps the taxpayer can undertake to culminate the APA process). The first pre-filing APA meeting, then, should help the IRAS and the taxpayer identify critical focus areas (e.g., where the IRAS and the taxpayer will require additional information, documentation, and analysis.)14

The IRAS discourages “anonymous” involvement on the part of tax professionals. Tax professionals had contacted the IRAS on some occasions. The IRAS does not encourage anonymous requests but will meet on that basis if the tax professional can demonstrate that there are sound reasons to do so.

The IRAS cautions the taxpayer that the lack of crucial information is likely to place severe limitations on the APA for that taxpayer. This lack of information is likely to impair the validity of any views that the IRAS provides incident to a meeting on a proposed APA. These “anonymous” meetings do not constitute pre-filing APA applications. The taxpayer, then, is strongly advised to engage the IRAS, doing so without masking its identity, if the taxpayer is serious about applying for an APA.15

FORMAL APA SUBMISSION PROCEDURES

The IRAS might agree during the pre-filing meeting with the taxpayer that the appropriate next step is to submit an APA application. The supplementary circular implies that the IRAS will provide a deadline to the taxpayer in submitting the APA application. This deadline might be reasonable as the IRAS is acting on data that might become stale quickly. That time period is not less than six months before the first day of the proposed covered period. The taxpayer should undertake “active steps” to submit its APA application no longer than the specified date. The IRAS can extend these time periods.16

A specific rule applies to bilateral APAs and to multilateral APAs. There the taxpayer should submit its APA application at the same time to both the IRAS and to the competent authorities of the relevant foreign tax jurisdictions. The APA application deadline for the foreign jurisdiction may be earlier than the six months that applies in Singapore. In that event, the taxpayer should submit its APA application concurrently to the IRAS and to the foreign tax jurisdiction at the same earlier date. The taxpayer is forewarned that failure to meet this timing requirement may cause the IRAS to reject the taxpayer’s APA application.17

The APA application the taxpayer submits should include all of the key information components in the main transfer pricing circular. The IRAS needs at least three hardbound copies of the APA submission and one soft copy of the submission. Filing a complete and comprehensive APA submission is instrumental in speeding up the APA review and negotiation process.18

APA REVIEW AND NEGOTIATIONS: CONSIDERATIONS AND REQUIREMENTS

The IRAS will further evaluate the contents of the APA application upon its receipt of the APA application from the taxpayer. The IRAS might then seek further clarification from the taxpayer if necessary.19

The IRAS has agreed to inform the taxpayer within one month of the IRAS’s receipt of the taxpayer’s application as to the IRAS’s acceptance of the APA application or otherwise.20 The taxpayer should be aware of these situations:

  • The IRAS might agree to accept the taxpayer’s APA application. In the case of a bilateral APA or a multilateral APA, in the event that the IRAS does accept the APA application, the taxpayer has limited resources. The IRAS will proceed to contact the competent authorities of the relevant foreign jurisdictions to initiate the APA review and negotiation process.
  • The IRAS might decline to accept the taxpayer’s APA application. If the IRAS does decline the taxpayer’s APA application, the IRAS would then fully explain the grounds for declining the request.

The IRAS and the other competent authorities concerned have the discretion to accept or reject an APA application. Nevertheless, without reserving the power to accept or reject the APA application, the IRAS is unlikely to decline the APA application if the taxpayer has complied with the requisites and procedures pertaining to pre-filing and submission of the APA application mentioned in the preceding paragraphs. The IRAS can, however, express its reservations on the appropriateness of the APA application during its pre-filing discussions with the taxpayer.21

The supplementary circular provides information to taxpayers concerning the scope of the IRAS’s acceptance of the APA application. A taxpayer that makes an APA application should note that acceptance of the APA application does not mean the IRAS has accepted the specific facts of the APA application. In other words, the IRAS can accept the taxpayer’s APA application without necessarily accepting in its entirety the taxpayer’s proposed transfer piecing methodology or other variables (e.g., arm’s length range, etc.) put forth in the APA application. The IRAS reserves the right to propose alternative methodologies, whether doing so on its own or in consultation with a treaty partner in a bilateral APA situation or a multilateral APA situation. The IRAS also can request an expansion or restriction to the proposed APA even after the taxpayer formally submits the APA application.22

The IRAS, in the course of the APA review and the negotiation process, might find it necessary to request additional information from the taxpayer. Such additional information can include different levels of segmental data related to the APA covered transactions if the taxpayer did not previously provide this information. The IRAS warns that the taxpayer’s “full cooperation and proactive support” in providing the requisite information to the IRAS is critical to the success of the APA process.

The supplementary circular provides that the IRAS is “committed to do its best” to expedite the APA review and the negotiation process. Nevertheless, the time taken by the taxpayer to respond to further information and clarification requested by the IRAS is also critical in determining the pace of progress of the APA review and the negotiation process. The taxpayer should take proactive steps to share with the IRAS any new facts and information that are likely to affect the outcome of the APA process.23

A special IRAS APA procedure applies to bilateral APAs and to multilateral APAs. As part of this APA procedure, the IRAS and/or its negotiation partners may require the taxpayer and/or its covered entities to submit additional information in response to queries raised by the competent authorities of the foreign tax jurisdictions concerned. The taxpayer is obligated to inform the IRAS when the taxpayer receives such queries from the relevant foreign competent authorities. The taxpayer should simultaneously submit to the IRAS any information submitted to the foreign competent authorities. The taxpayer should update the IRAS on a timely basis on the discussions of any meetings that the taxpayer and/or covered entities of the APA might hold with the relevant foreign authorities.24

The IRAS implicitly takes the position that the taxpayer will not be part of the APA review process nor the APA negotiation process. The IRAS, for its part, will also keep the taxpayer regularly updated on the outcome of the APA review process and the negotiation process.25 Taxpayers should be cautious of the “updated on the outcome” phraseology in the supplementary circular as this term may connote the desire on the part of the IRAS to remove the taxpayer from the negotiation process altogether as if the treaty partners were part of mutual agreement procedure negotiations.

APA ROLL-BACK

The supplementary circular points out that the taxpayer, in some instances, may request an APA for a covered period to apply to certain prior years. This retroactive request is referred to as a “roll-back.”26

The IRAS will consider the taxpayer’s request to apply the APA to roll-back years only for bilateral APAs and multilateral APAs. The IRAS will consider the taxpayer’s request based on:27

  • The merits of the taxpayer’s request
  • That there are “no significant changes” to the facts and circumstances during the roll-back period
  • That the transfer pricing methodology remains current to these earlier time periods

The taxpayer is expected to maintain relevant documents to substantiate the above facts. As a general manner, the IRAS might accept a roll-back period of up to two years prior to the proposed APA covered period.

Taxpayers outside of Singapore as well as taxpayers in Singapore itself are cautioned that the IRAS will not consider requests for the APA to apply to roll-back years in the case of unilateral APAs.28 The supplementary circular failed to provide a rationale for that unilateral APA limitation.

DISCONTINUATION OF THE APA PROCESS

The IRAS will discontinue the APA process for a number of reasons, including when:

  • The taxpayer does not submit the APA application after the expiration of specified time frame
  • The taxpayer does not provide a sufficient level of support during the APA process
  • There is an absence of communication or complete information

The IRAS stresses strongly that the success of the APA process:

  • Is a highly time-consuming and resource-consuming process for the IRAS
  • Requires the taxpayer to “consistently demonstrate full cooperation and active support efforts” throughout the entire APA process

The IRAS expects the taxpayer to “act in good faith with the IRAS” throughout the APA process. Similarly, the IRAS expects the taxpayer to be forthcoming in providing “complete and reliable information” relating to the APA application. This information includes any communication the taxpayer may have with the relevant foreign competent authorities and includes any information provided to the relevant foreign competent authorities. The IRAS may consider discontinuing the APA where these elements seem to be absent or are not forthcoming during any part of the APA process.29

The IRAS provides a number of examples of the circumstances that would warrant the IRAS’s discontinuing the APA process. These examples illustrate the approach the IRAS would take in these circumstances.30

NONSUBMISSION OF THE APA APPLICATION

The IRAS expects that where the IRAS and the taxpayer have agreed, during a pre-filing meeting, that the appropriate next step is for the taxpayer to submit an APA application, the taxpayer would take active steps to submit the APA application, doing so no later than the agreed specified application date unless the IRAS extends the application date. If the taxpayer does not submit the APA application by the specified application date, the IRAS is entitled to consider the taxpayer as not longer interested in pursuing the APA application process.31 The supplementary circular does not address the procedure under which the taxpayer can seek to extend the APA extension date.

The IRAS provides taxpayers with a rule of thumb to assuage the taxpayer’s continued interest in the APA application. The IRAS will consider a taxpayer as having no further interest in pursuing the APA application if the IRAS does not receive further information from the taxpayer regarding the application within six months from the date of the most recent pre-filing meeting.32

INSUFFICIENT LEVEL OF SUPPORT DURING THE APA PROCESS

The IRAS is likely to need to request additional information and other support from the taxpayer during the APA review process and the negotiation process. In this regard, the IRAS expects to receive full cooperation and proactive support from the taxpayer on a timely basis. The IRAS expects the taxpayer to provide to the IRAS accurate, good-quality information and analysis in response to the IRAS’s information requests.33

As part of the APA review process, the IRAS seeks to agree with the taxpayer on the expected time frame by which the taxpayer should submit the additional information that the IRAS seeks. The IRAS will consider the taxpayer as having withdrawn from the APA process if the taxpayer fails to respond to information requests by the specified time frame and the information requested by the IRAS remains outstanding for an extended period of time.34 The IRAS, as a rule of thumb, will consider the APA process as having been discontinued by the taxpayer if the taxpayer fails to provide requisite information to the IRAS within three months after the agreed expected time frame by which the IRAS is due to receive the information.35

ABSENCE OF COMMUNICATION

The IRAS evaluates the APA application based on the specific facts and information the taxpayer furnishes to the IRAS in the APA application. The taxpayer has an obligation to provide any relevant and material facts or information to the IRAS on a timely basis. These relevant and material facts or information are those items that would affect the outcome of the APA on a timely basis.36

The next example illustrates the materiality of the communications requirement. The taxpayer and/or the covered entities in a bilateral APA or multilateral APA can communicate with the relevant foreign competent authorities concerned, or the taxpayer and/or the covered entities in a bilateral APA or multilateral APA can provide them with additional information in response to their queries. Such information being transferred is likely to affect the outcome of discussions between the competent authorities. As a result, the supplementary circular requires the taxpayer to update the IRAS, on a timely basis, about the details of all such communications with the foreign relevant competent authorities concerned. The IRAS reserves the right to discontinue the APA process if it is subsequently determined that the taxpayer failed to provide material information to the IRAS and this information could have affected the outcome of the APA.

The IRAS can consider the timeliness for pre-filing and the timeliness of the formal application on a fresh basis. The taxpayer can express a wish to resume the APA process or seek to discuss the same APA application. The taxpayer can treat the application as if it were a new APA application subject to acceptance by the IRAS. The IRAS may take into account its prior experience in assessing the acceptability of the new application. The IRAS reserves the right to accept the new APA application. If the IRAS were to accept the new APA application, the IRAS will process this application and prioritize the application relative to other cases that the IRAS might already be processing. In this regard, the IRAS will treat unilateral, bilateral, and multilateral APA applications in the same manner.37

EFFECTIVE DATE

The IRAS will apply the administrative guidance provided in the supplementary circular to APA requests made on or after October 20, 2008. The taxpayer might have difficulty in applying the administrative guidance for a prior period before October 20, 2008. The IRAS will consider these taxpayer requests on a case-by-case basis.38

NOTES

1. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 1.

2. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 2.

3. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 3.

4. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 4.

5. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 5.

6. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 6.

7. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 7.

8. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 8.

9. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 9.

10. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 10.

11. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 11.

12. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 12.

13. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 13.

14. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 14.

15. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 15.

16. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 16.

17. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 17.

18. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 18.

19. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 19.

20. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 20.

21. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 21.

22. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 22.

23. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 23.

24. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 24.

25. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 25.

26. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 26.

27. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 27.

28. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 28.

29. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 29.

30. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 30.

31. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 31.

32. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 32.

33. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 33.

34. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 34.

35. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 35.

36. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 36.

37. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 37.

38. Supplementary Administrative Guidance on Advance Pricing Arrangements, October 20, 2008, Sec. 38.

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