Certainty, agreed in advance.
An advance pricing agreement settles the transfer pricing of a transaction with Inland Revenue before the returns are filed. Both partners have negotiated APAs, including for a significant inbound loan.
- Senior-ledA partner on every engagement
- Big 4 depthFormer leaders of NZ’s largest TP practice
- NZ and AustraliaGlobal reach through TPA Global
Everything the matter needs, nothing it doesn’t.
- APA feasibility assessment and strategy
- Preparation of the APA application and supporting analysis
- Negotiation with Inland Revenue
- Bilateral APAs and competent authority coordination with the other jurisdiction
- Annual compliance reporting and renewals
Signs it is time to talk.
Groups with significant or unusual transactions that want certainty, and groups coming out of a dispute.
- A transaction is large enough that an adjustment would be material
- The arrangement is unusual and comparables are thin
- You want to avoid double taxation on a cross-border transaction
- A review has ended and you want to lock in the position going forward
Four steps. No surprises.
A confidential discussion
A partner listens to the situation and tells you whether there is something to do.
A clear scope and fee
Written scope, a fixed or capped fee where we can, and the partner who will do the work.
Senior analysis
The partners do the thinking: facts, economics, the law and how Inland Revenue will see it.
Advice that holds up
Documentation and advice written knowing it may one day be read by a reviewer.
Good questions.
What is the difference between a unilateral and a bilateral APA?
A unilateral APA is agreed with Inland Revenue only. A bilateral APA also involves the tax authority of the other country through the mutual agreement procedure in a tax treaty, which removes the risk of double taxation.
How long does an APA take?
It depends on the complexity of the transaction and whether another authority is involved. Unilateral APAs are generally faster. We give a realistic estimate after the feasibility stage.
Often needed together.
Let’s talk about your situation.
A confidential discussion with a partner costs nothing and usually tells you within half an hour whether there is something to do. Call Mark or Ranesh directly, or send a brief outline and we’ll come back to you within one business day.