An APA provides certainty on the treatment of specified transactions for a defined period. It merits serious consideration where transaction values are material, the methodology is genuinely open to argument, or the same arrangement will recur over several years.
The service covers:
- Assessment of whether an APA is the right instrument, and whether a unilateral, bilateral or multilateral agreement is appropriate
- Preparation for and attendance at the pre-filing conference with the tax authorities
- Preparation of the formal application — functional analysis, proposed methodology, benchmarking, critical assumptions and financial projections
- Management of the information request process throughout the review
- For bilateral applications, support for engagement with the competent authority of the counterparty jurisdiction
- Annual compliance reporting and monitoring of critical assumptions once in force
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