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KPMG’s Leader, Global Transfer Pricing
FRANCOIS VINCENT: One of the most common questions that get’s asked about APAs is, what are the benefits and drawbacks? Clients are often looking for a comparison of cost, sort of a cost-benefit ratio between APAs and not doing APAs. So for a number of clients, we’ve done the exercise of saying, okay, what is the cost of documentation, and then defending that position through an audit, and then going to appeals, and/or competent authority or even litigation, and if you think about the number of audit cycles that could be covered by an APA and rollback, you can do a pretty good comparison. So for instance, one of the most common comparisons will have something like three audit cycles, when I say audit cycles, of course, its audit defense, competent authority, and that compares with one APA with a fairly routine rollback. APAs are always a better deal. The only thing about APAs is that you sometimes have to put up the money upfront, but the benefit may last for at least five years, plus renewals are much simpler, so your.
Francois Vincent, KPMG’s Leader, Global Transfer Pricing Dispute Resolution discusses the pros and cons of pursing an APA.
Navigating APAs home
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