• Service: Tax, Global Transfer Pricing Services, Topics, Tax Reform
  • Type: Survey report
  • Date: 1/05/2012

Navigating APAs: A global review of Advance Pricing Arrangements 

Global companies face ever more risk of disputes with tax authorities over their transfer pricing practices. To mitigate this risk, many companies are opting to enter formal Advance Pricing Arrangements (APAs) with one or more tax authorities.
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KPMG conducted in-depth interviews with tax directors (or their equivalents) from 25 multinational companies in seven countries to explore current perceptions and experiences with APA programs.


Findings were analysed by a panel of transfer pricing leaders from a number of KPMG firms. This report discusses the findings.


Key questions included:

  • Are APA programs operating efficiently and effectively?
  • Are businesses finding that the comfort that their transfer pricing policies will not be challenged is worth the cost and effort of negotiating these agreements?
  • Are there steps that taxpayers can take to ease the process and get better results?
  • Are they getting what they need from their transfer pricing advisors?
  • Are there opportunities to fine-tune these programs to make them simpler and more effective for everyone involved?

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