Rule 104 makes eligible to enter into an advance pricing agreement any person who has undertaken, or is contemplating undertaking, an international transaction.
104
Rules 2026 · Rule 104
Persons eligible to apply (advance pricing agreement)
Rules 77-130
The rule. A person is eligible to enter into an agreement under these rules if the person (a) has undertaken an international transaction, or (b) is contemplating undertaking an international transaction.