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:
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.
Of the 25 respondent companies that took part in the survey:
The experiences of tax authorities and taxpayers with its compilation of global survey data about the APA programs operating around the world.