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Dispute Avoidance: Advance Pricing Agreement

Deloitte Tax LLP

Deloitte's transfer pricing professionals assist clients with all aspects of defending their transfer prices before the tax authorities and with local audit teams. If an audit results in a transfer pricing adjustment, Deloitte helps obtain double tax relief through the tax treaty competent authority process. Deloitte also helps clients negotiate Advance Pricing Agreements (APAs) to obtain prospective transfer pricing certainty.

An APA offers a means of obtaining tax authority approval of your transfer pricing policies and methodologies up to five years in advance. An APA makes sound financial sense because it may 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 while potentially reducing penalties and 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 optimal value of an APA in several important ways:

  • Our specialists and economists have the broad experience and in-depth 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 in-depth 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.

Learn more about Deloitte's Advance Pricing Agreement Services.  

As used in this document, “Deloitte” means Deloitte Tax LLP. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

 

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