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An advance pricing agreement (APA) is an ahead-of-time agreement between a taxpayer and a tax authority on an appropriate transfer pricing methodology (TPM) for a set of transactions at issue over a fixed period of time [1] (called "Covered Transactions").
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The value of the consideration may be for a nominal amount only. A framework agreement, or an "umbrella agreement", lacks consideration and therefore lacks obligation: a "pricing formula" may apply for a period of time (e.g. a price list) or prices and further details may be determined via a "mini-competition". [11]
The discussion in this section explains an economic theory behind optimal transfer pricing with optimal defined as transfer pricing that maximizes overall firm profits in a non-realistic world with no taxes, no capital risk, no development risk, no externalities or any other frictions which exist in the real world.
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It is a specific type of exit provision that may be included in a shareholders' agreement, and may often be referred to as a buy-sell agreement. The shotgun clause allows a shareholder to offer a specific price per share for the other shareholder(s)' shares; the other shareholder(s) must then either accept the offer or buy the offering ...
According to the PMBOK (7th edition) by the Project Management Institute (PMI), Fixed Price Economic Price Adjustment Contract (FPEPA) is a "fixed-price contract, but with a special provision allowing for predefined final adjustments to the contract price due to changed conditions, such as inflation changes, or cost increases (or decrease) for special commodities".
An escalation clause is a clause in a lease or contract that allows for a change in the agreed-upon price in response to a specific factor that is outside of the control of either party. This type of clause is used to protect against potential changes in the value of the goods or services being exchanged, such as in cases of inflation or other ...
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