Globalization, Multinationals and Tax Base Allocation: Advance Pricing Agreements as Shifts in International Taxation?

Abstract: This paper elaborates on the emergence of so-called Advance Pricing Agreements (APA) in international taxation and corresponding APA programs in individual countries. It refers to how globalizing business processes trigger governance change on the nation state level regarding the identification and allocation of the tax base of multinational companies. The introduction of APA programs and the generation of APAs are considered to be an example of such governance change.…