Transfer Pricing Dispute Prevention

Are you tired of dealing with relentless transfer pricing disputes and uncertainty? An Advance Pricing Agreement (APA) may be the solution for you!

An APA is a written agreement made between Director-General of Taxes and the Taxpayer (Unilateral APA); or Director-General of Taxes and the Competent Authority of the Treaty Partner and the taxpayers concerned (Bilateral APA). The agreement governs the transfer pricing treatment  applied by tax authorities and taxpayers including the determination of the arm’s length price or profit in advance for upcoming five fiscal years and roll-back periods.

An APA offers certainty and predictability on transfer pricing arrangements between related parties and effectively reducing the risk of disputes with tax authorities. Nevertheless, the APA process can be time-consuming and complex.

Our specialized team has a proven track record of successfully obtaining APA’s for our clients, saving them time and money in the long run.

Our APA services include:
  • •Reviewing your current transfer pricing arrangements
  • •Identifying potential areas of dispute with tax authorities
  • •Developing a comprehensive APA application package approach
  • •Representing your business in negotiations with tax authorities
  • •Ongoing support throughout the APA process, including renewals and amendments

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Connect us today to learn how our  experienced team can support you in obtaining an Advance Pricing Agreement.

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