Advance pricing agreements

Advance pricing agreements

Because they operate in an increasingly regulated business environment, where transparency is key, taxpayers need a certain degree of certainty in managing their tax and their potential exposure to risk. Advance pricing agreements (APAs) help provide taxpayers with that certainty.

PKN alerts
The PKN provides alerts apprising you of the impact of major transfer pricing, tax, and related developments within hours of news breaking.
Learn more

Transfer pricing in the news
News and views from PwC's Transfer Pricing practice with articles covering the significant transfer pricing developments impacting your company.
Learn more

Transfer pricing publications
Learn more

The Global Tax Monitor
The Global Tax Monitor¹ recognises PricewaterhouseCoopers as the leading firm globally for transfer pricing, by reputation, with a very strong lead over the competition. These results are based on the year-ending Q2 2009 figures, with a sample size of 3,246 primary buyers of tax services globally.
Learn more

An APA is a contract, usually for multiple years, between a taxpayer and at least one tax authority specifying the pricing method that the taxpayer will apply to its related-company transactions. These programmes are designed to help taxpayers voluntarily resolve actual or potential transfer pricing disputes in a proactive, cooperative manner, as an alternative to the traditional examination process.

Although styled as "advance" agreements, APAs often involve the resolution of transfer pricing issues pending from prior years—and in some cases can provide an effective means for resolving existing transfer pricing audits or adjustments.

An APA offers a company several other benefits. It provides greater certainty on the transfer pricing method adopted, mitigating the possibility of disputes and facilitating the financial reporting of potential tax liabilities. Importantly, an APA also reduces the incidence of double taxation, and the costs associated with both audit defence and documentation preparation.

How we can help

Assistance with APA requests is one of the key offerings of PricewaterhouseCoopers' global tax controversy and dispute resolution network. We have substantial experience helping companies across a diverse range of industries obtain APAs covering a broad spectrum of intercompany transactions. Many of our professionals hail from academia, industry, and prominent positions within governments—including senior-level positions in governmental agencies responsible for administering APAs.

We can work with you to develop strategies at both the global and local level, and guide you through the process of requesting APAs to help you ensure successful outcomes.

¹ TNS Global Tax Monitor data, Q2 2009. The Global Tax Monitor is a multi-client independent survey of more than 3,000 key tax decision makers per annum (CFOs and Tax Directors) in 31 key markets worldwide.