A Five-Phase Strategy
Deloitte Tax LLP
Deloitte Tax LLP combines research, analysis and negotiation in our intensive five-phase approach to obtaining advanced pricing agreements (APAs):
Phase 1: Indepth analysis and strategy development. We learn how your company operates and determine what value is contributed to transactions by each entity. This becomes part of your supporting data for an APA and prepares us to evaluate potential arguments on your behalf.
Phase 2: Prefiling. Deloitte Tax holds prefiling conferences with tax authorities in which we discuss your situation in general terms and gauge reactions. This helps us advise you about the possibilities of proceeding with the APA process.
Phase 3: Negotiation. After formally submitting your application, Deloitte Tax engages in open, nonadversarial negotiations with the tax authorities, inviting them to visit sites, ask questions and identify areas of concern. Deloitte Tax will then help you negotiate a satisfactory conclusion.
Phase 4: Finalization. In this fast-moving phase, Deloitte Tax obtains agreement from all relevant authorities and finalizes the contractual language of the APA.
Phase 5: Administration. Once the APA is in place, Deloitte Tax prepares a brief annual report for tax authorities, demonstrating that you are operating within the parameters of the agreement.