A proactive approach to managing global transfer pricing disputes can enhance both efficiency and effectiveness.
Transfer pricing (TP) continues to claim the attention of tax authorities around the world. International disputes - and the need for resolutions - have risen as a result of the heightened level of TP examination activity. Active multinationals increasingly experience inconsistencies worldwide in the interpretation and enforcement of TP rules.
Our Guide to advance pricing agreements (APAs) outlines the dynamic TP landscape worldwide and how to proactively navigate it with APAs. Topics covered include:
- Advance pricing agreements (APAs): the basic elements
- Benefits of an APA for taxpayers
- APA process
With the current economic recession, many companies have suffered a reduction in profits and in many cases undergone business restructuring, which, according to information gathered from tax authorities for the 2009 Ernst & Young transfer pricing survey, are the two most common examination triggers.
We are committed to the strategic global management of TP issues, working with taxpayer personnel to anticipate and address TP disputes at the earliest stage.
APA programs worldwide
At the same time as TP documentation requirements grow, more countries are adopting Advance Pricing Agreement (APA) programs as a way to address evolving TP issues worldwide. As of January 2011, more than 30 countries allow APAs, among those countries are: