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.
- Senior Counsel