An Advance Pricing Agreement (APA) offers a means of securing tax authority approval of your transfer pricing policies and methodologies up to five years in advance. An APA makes sound financial sense because it can save you money, boost cash flow and mitigate risks by meeting information challenges up front, eliminating onerous and time-consuming documentation requirements later on and obtaining agreement about your proceedings without concern about penalties or double taxation.

Our transfer pricing specialists can help you secure this “five-year stamp of approval” through an APA application. If you have a solid position and can demonstrate the reasonableness of your position, you can virtually eliminate the uncertainty and the exposure of a day-to-day approach to transfer pricing issues. The governments involved will review your books, your business and your transfer pricing proposals, with the ultimate goal of granting an APA that agrees in advance with a particular methodology governing your transactions. We can also conduct open and cooperative negotiations on your behalf with involved government representatives, ensuring that you receive a fair and professional evaluation of your transfer pricing strategies—and that any disputed issues are quickly resolved. 

What makes our service different?

We help you obtain the maximum value of an APA in several important ways:

• Our specialists and economists have the broad experience and indepth knowledge to develop, support and negotiate proposed transfer pricing methodologies.
• We understand the issues that attract the attention of tax authorities, including APAs.
• We can often anticipate and influence emerging transfer pricing issues and steer actions toward innovative solutions.
• Our organization enjoys a top reputation among tax authorities for professionalism and ethics, resulting in a more cooperative and productive negotiating environment.
• Our transfer pricing specialists use a five-phase strategy for APAs that involves both indepth analysis and negotiation. Use the strategy hyperlink to get more information on how these steps work.

Get more information on efficiencies that can be achieved with an APA.