Obtaining prospective tax certainty with Advance Pricing Arrangements

Are you protected from transfer pricing issues that may result in high penalties?

Advance Pricing Arrangements (APAs) offer multinational organizations relief from potentially expensive and difficult audits. They are formal agreements with a specialized group within the local tax administration to a mutually acceptable transfer pricing methodology for intercompany transactions. APAs can last up to five years, and can also apply to previous years in certain circumstances.

Is an APA right for you?

An APA provides a non-confrontational way to obtain certainty with your transfer pricing policies and to minimize transfer pricing audits that otherwise could take years to finalize. They are recommended for companies that have:

• A history of long, drawn-out audits followed by reassessments that take years to resolve through the appeal or competent authority processes
• Complex intercompany transactions
• A high degree of risk of reassessment that may result in significant penalties
• A desire to obtain certainty with their transfer pricing polices

How PricewaterhouseCoopers can help

Our Transfer Pricing practice has extensive experience helping organizations obtain the maximum value from their APAs. We will leverage expertise from our global network to assist you wherever you require support.

Contact a transfer pricing professional to discuss how we can help you with the APA process.