Business Services Industry
Using an APA may help avoid an audit.
Australasian Business Intelligence, November, 2006
Byline: Mindy Piatoff
Nov 13, 2006 (Tax Planning International Transfer Pricing - ABIX via COMTEX) -- The Internal Revenue Service views transfer pricing and the offshore transfer of intangibles as among the biggest US tax compliance problems. The tax departments of multinationals treat transfer pricing as a priority. It can be worthwhile for multinationals and middle-market companies to obtain an advance pricing agreement (APA), which reduces the risk of a tax audit. Over 600 APAs have been negotiated during the 15 years of the APA program. Companies must decide whether to obtain a unilateral or bilateral APA, what lines of business the APA should cover, and whether to include rollbacks.
Publication Date: September 2006
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