Advance Pricing Agreements (APAs) are legally binding agreements between the taxpayer(s) and the tax authorities that are used to obtain prior clarity on the application of transfer pricing methods and/or rules for a particular set of transactions.
Transfer Pricing Agreement
Transfer Pricing Agreement
Structuring, documenting, and defending transfer pricing agreements with confidence
When it comes to transfer pricing agreements, two distinct categories matter:
- Agreements with tax authorities. For example via an Advance Pricing Agreements (APAs).
- Agreements between your own entities. For example via Intercompany Agreements and Cash pool agreements.
Below is a concise overview of each, with links to our deep-dive pages so you can get the details you need.
Since we are 100% focused on our passion for Transfer Pricing, Quantera Global is here to give you a clear answer, no matter how complex your question. Continue reading about transfer pricing agreements, or schedule a strategic session straightaway.
Theo Elshof
Managing Director
Want to know more about Transfer Pricing Agreement?
Get in touchAdvance Pricing Agreements (APAs) are binding agreements you negotiate with one or more tax authorities to lock in your transfer pricing methodology for future years. They provide certainty and minimize audit risk.
- Unilateral APA: agreement between the taxpayer and one tax authority.
- Bilateral APA (BAPA): agreement between the taxpayer and two tax authorities.
- Multilateral APA (MAPA): agreement between the taxpayer and more than two tax authorities.
- Mutual Agreement Procedures (MAPs): a post-audit process where tax authorities collaborate to resolve double-taxation issues.
These transfer pricing agreements matter because they lock in your arm’s-length pricing, reduce uncertainty, and help avoid lengthy audits or adjustments.
The APA 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. Quantera Global can assist and guide you through the APA process and do so for various MNEs and SMEs on a weekly basis.
Schedule a free consultation by phone or learn more about APAs and MAPs in our webinar:
Webinar: Advance Pricing Agreements (APAs) & Mutual Agreement Procedures (MAPs)
Transfer pricing agreements between your entities
While APAs address external certainty, intercompany agreements (ICA) formalize your internal transactions. Clear contracts ensure consistency and compliance with your APA or general transfer pricing rules.
Intercompany agreements document your chosen pricing methods and terms, support audit defense, and streamline internal billing.
It is very important that the ICA is in line with reality, consistent with transfer pricing documentation and in line with market standards. Quantera Global can assist your company in drafting these agreements. And we ensure that all these important aspects are included in the agreement. Depending on your wishes, we can work with your inhouse legal counsel or an external legal counsel in preparing such intercompany agreements or conduct a review.
We are here of you need help with:
Transfer pricing agreement templates
Looking for a transfer pricing agreement template? We are here to help! Request a template via our contact form, or jump straight to a transfer pricing service: sparring partner, strategic session, transfer pricing analysis.
We are here of you need a:
Learn more about Transfer Pricing Agreements
Did we leave your question unanswered? Let us know! Ask you question in a free phone consultation or use our contact form. We are looking forward to meeting you. In the meantime you can subscribe to our Transfer Pricing newsletter.
Our greatest success is your success.
"Quantera Global has assisted us in a transfer pricing documentation project that needed to be dealt with on a short notice. We appreciate their delivery capacity and proper and timely feedback."
Erwin Beermann
CFO at FibrXL
"Quantera Global knows the ins and outs of transfer pricing and they listen well to understand your situation and provide to-the-point support with concise reports. In addition, they have a strong local and international network of specialists which they match well."
Stijn Kalkers
Manager Finance & Accounting at Apex International