Advance pricing agreements offer audit assurance
November 10, 2010
Shiv Mahalingham of Alvarez & Marsal (Taxand UK) deconstructs international approaches to APAs and explains how the agreements can help prevent unexpected adjustments, interest or penalties in transfer pricing audits.
Businesses spend a significant amount of management time on transfer pricing, often engaging advisers to prepare extensive transfer pricing reviews, in an attempt to mitigate the impact of a potential transfer pricing audit. However, given the subjective nature of transfer pricing, adjustments may still be sought by tax administrations and the dispute resolution process can be gruelling.
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