An Advance Pricing Agreement is a formal agreement with one or more tax authorities on the transfer pricing treatment of specific transactions for a defined period.
APAs are used where certainty matters. They can reduce audit risk, prevent disputes, and provide a stable framework for complex or high value arrangements. At the same time, they require careful preparation, coordination, and a clear view on whether the effort is proportionate.
We advise on APAs with a strong focus on judgment, feasibility, and execution.
An APA is typically considered when:
Not every situation calls for an APA. Part of our role is to assess whether an APA is the right tool or whether other options achieve sufficient certainty with less complexity.
We support clients throughout the full APA lifecycle, from early feasibility assessment to negotiation and implementation.
Our work typically includes:
Each APA is led by a senior transfer pricing professional who remains closely involved throughout the process.
APAs often involve more than one tax authority. Effective coordination is essential to avoid inconsistent positions, delays, or unnecessary escalation.
We manage APA projects with:
Local expertise is brought in where needed, while overall ownership and strategy remain central. senior transfer pricing professional who remains closely involved throughout the process.
Clients working with us on APAs can expect:
If an APA is unlikely to deliver proportionate value, we will say so early.
APAs are powerful tools, but they are not always the most efficient solution.
In some cases:
may achieve sufficient certainty with less burden. We help clients weigh these options before committing to a multi-year APA process.
If you are considering an APA or want to assess whether it makes sense for your situation, we are happy to discuss scope, feasibility, and next steps. Please make an appointment for a free consultation by phone or fill in our contact form. We are looking forward to meeting you.
Managing Director
