Bilateral and multilateral Advance Pricing Agreements involve two or more tax authorities agreeing on the transfer pricing treatment of specific transactions for a defined period.
BAPAs and MAPAs are typically used where cross-border transactions create material double taxation risk or where consistent treatment across jurisdictions is essential. They offer a higher level of certainty than unilateral APAs, but also require stronger coordination, longer timelines, and careful management of authority interactions.
We advise on BAPAs and MAPAs with a strong focus on feasibility, coordination, and execution.
Bilateral or multilateral APAs are commonly considered when:
They are not always the right first step. Part of our role is to assess whether a bilateral or multilateral APA is proportionate, or whether other dispute resolution or certainty tools are more suitable.
We distinguish three forms of APAs, namely:
Bi-/multilateral APAs usually take longer to obtain because more than one tax authority is involved. Partly for this reason, bi-/multilateral APAs are more complex and costly. Nevertheless, bi-/multilateral APAs can be a great solution for cases in which there is a (material) transfer pricing risk in multiple jurisdictions. For example, if you expect one tax authority would take an unreasonable position it may be beneficial that there is also another tax authority at the table to convince them otherwise instead of just yourself as taxpayer.
Once such Bilateral APA (BAPA) or Multilateral APA (MAPA) is obtained this significantly reduces your audit risk in those and other jurisdictions. It provides for a quality stamp on your transfer pricing policy that is also appreciated by (new) investors and auditors for example.
The BAPA and MAPA process can be complex if you have limited experience with it. It is quite common to involve a Transfer Pricing specialist, not only for the technical side but also to support in how to handle the process most optimally.
As Quantera Global, this is a field in which we have extensive expertise and experience. We have for example former heads of the Dutch APA practice with us, who handled BAPAs and MAPAs from tax authority and consultancy perspective and were selected by the European Union to support two tax authorities in streamlining their APA process. We can assist and guide you through the BAPA and MAPA process and can also act as sparring partner when you would like to start such process yourself.
If you would like to discuss how we can be of service to you, please make an appointment for a free consultation by phone or fill in our contact form. We are looking forward to meeting you.
Not sure your BAPA’s and MAPA’s are audit-ready? Get a free Transfer Pricing scan:
Managing Director
Catch red flags before tax authorities do, use our TP scan. A senior advisor will review your transfer pricing approach in a short call – free & confidential.