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.
We can assist you with responding, performing additional analysis as required, and with discussions with the Taxation Authorities throughout the process.