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Advance Pricing Agreements and Challenges of Country by Country Reporting
This chapter explores the potential increase in interest and applications for Advance Pricing Agreements (APAs) worldwide after the implementation of Pillar Two Safe Harbors. It also discusses the challenges taxpayers face regarding the timing of their country by country reports, emphasizing the need for taxpayers to review their internal C by C process and accelerate it to ensure reliance on the safe harbors.