Patricia Lewis and Clark Armitage to Moderate APA Workshop at 2014 Transfer Pricing Summit


Managing transfer pricing risk, particularly in light of recent policy developments such as the BEPS action plan, should be a priority for multinational enterprises (MNEs). Corporations are increasingly implementing more proactive approaches to managing TP risk by negotiating, outside a litigation context, an advance agreement or ruling with the authorities involved (APA). In the US, the IRS is making efforts to streamline the APA process, but is also seeking a fuller understanding of the business dynamics and increased transparency under newly revised procedures.  This workshop will outline how MNEs can develop their risk management strategy using APAs and rulings, and the presenters will highlight the opportunities available to corporations considering implementing or rethinking their APA strategy in response to the latest IRS and international TP policies.  The discussion will include methods for APA and CA submissions, best practices, and practical advice on how to efficiently navigate the current system.  The contrast -- or positive considerations -- in handling double tax audit disputes through MAP will also be addressed.

Coverage Includes:

  • IRS, foreign and OECD appetite for MAP and APAs
  • Potential role of "safe harbors"
  • Considering the trade-off between tax certainty, risk and optimisation
  • Options, procedures, and strategies relating to APA submissions
  • Unilateral versus bilateral versus multilateral agreements
  • Retaining control and managing the MAP/APA process
  • Practical examples


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