Advance pricing agreements (APAs) are advance agreements on transfer pricing methodologies, entered into by a multinational taxpayer and at least one government’s administration. Although APAs are styled as "advance" agreements, in fact they are often coupled with resolutions of pending transfer pricing issues of prior years. Therefore, APA proceedings can provide the opportunity to resolve transfer pricing issues over the past five years or more, as well as those of future years.
The PricewaterhouseCoopers advantage
Our transfer pricing team has much experience of helping clients to obtain APAs. Our strong international network means that we can assist you in whichever jurisdiction you require support, and we can help you to coordinate this approach cross border, as necessary.
