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KPMG’s Leader, Global Transfer Pricing
FRANCOIS VINCENT: One of the major benefits of APAs is indeed having a proactive approach and being sort of in control of the agenda, because in an APA, unlike an audit, in APA, the taxpayer proposes an approach, proposes a timeline, to a certain extent, everybody follows a certain timeline, but the client, the taxpayer is a lot more in control of the timeline when doing an APA vs. an audit. An audit, you’re very much at the mercy of the tax authority’s review and question of your affairs, and the questions may not go in the direction that you would like them to go, whereas in an APA, well, you set the agenda, you also set, to a certain extent, the issues you put in front of tax authorities and how you want to present your story, so that’s one of the major, major benefits of doing an APA, being able to tell your story in your own terms on your own agenda.
Francois Vincent, KPMG’s Leader, Global Transfer Pricing Dispute Resolution explains how an APA can help you take control over the transfer pricing process.
Navigating APAs home
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