Advanced Pricing Arrangement (APA)’s are agreements made with the Tax Office and/or with one or more foreign tax jurisdictions to agree prices paid in international related party dealings for a period in the future.
For many taxpayers, the magnitude of uncertainties which transfer pricing presents, and the potential commitment to management time to defend a transfer pricing audit, it is not a business risk they are willing to assume.
APAs give taxpayers the opportunity to achieve greater certainty on their transfer pricing outcomes.
We can provide our extensive expertise in a cost effective manner for companies interested in managing their transfer pricing issues on a prospective basis through an APA.
We have significant experience in assisting clients to manage their Tax Office audits, to defend the clients' prices and their documentation, and minimise penalties and interest.
We can assist you with responding, performing additional analysis as required, and with discussions with the Taxation Authorities throughout the process.