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APA Survey –  Introduction 

With APA activity on the rise and new programs coming on-stream in countries worldwide, we believe it is time to take stock of companies’ experiences with these programs by asking some fundamental questions.

The ongoing global economic crisis and its impact of tax revenues are spurring governments around the world to heighten transfer pricing enforcement. Global companies face ever more risk of disputes 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. APAs offer security that the selected transfer pricing methodology will be accepted over a fixed timeframe.


To explore current perceptions and experiences with APA programs globally, in-depth interviews were conducted with tax directors (or their equivalents) from 25 multinational companies in seven countries. Respondents were asked:


  • 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?
  • 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?

The findings were reviewed and analyzed by a panel of Transfer Pricing Leaders from a number of KPMG member firms. The report Navigating APAs,  is the result of their considerable collective experience in dealing with APA programs.

Respondent profile – At a glance

Of the 25 respondent companies that took part in the survey:


  • six companies have one APA in place
  • fifteen companies have two or more APAs in place and/or in negotiation
  • four companies have no APAs
  • one company is negotiating its first APA
  • some respondents had negotiated APAs in previous roles with other companies.

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