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 transfer pricing scan.
Want to know more about Transfer Pricing Agreements?
Emile Monfils
Managing Director
Transfer pricing agreements with tax authorities
Advance 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.
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.
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Sparring partner
Sparring partner Many of our clients are experiencing various developments in their business. They like to have a sparring partner who understands their business and its position and who can provide pragmatic advice in a quick and efficient way by addressing only the needs of the company. We enjoy being a sparring partner and are […]
Strategic sessions
In the strategic session, our experts gain a deep understanding of the composition and structure of your company, even in the most complex situations. Our team is specialised in understanding your business. The strategic session can focus on a specific topic you would like to focus on or your overall transfer pricing policy.
Transfer pricing analysis
All transactions between related entities should be at arm’s length. This is a very important principle in international tax law. A transfer pricing analysis is required to determine the arm’s length price. The tp analysis will show whether there are opportunities and possible threats within the current transfer pricing policy.
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