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Dispute avoidance: Advance pricing agreements
Transfer pricing presents many tax, legal and operational challenges. To many taxpayers the magnitude of uncertainties – including the potential commitment of significant management time in the event of a transfer pricing examination – is not an acceptable business risk. APAs allow taxpayers to achieve greater certainty via advance agreements on their transfer pricing methods with one or more tax authorities.
Deloitte's experience with the APA process spans the development of the national programs and this historical knowledge and insight combined with more recent practical experience helps us help companies to manage their transfer pricing issues – particularly the risk of double taxation – on a prospective basis.