Multilateral Advance Pricing Agreements

As transfer pricing examination and controversy continue to grow, it's becoming increasingly common for a multinational enterprise group to have advance pricing agreements (APA) with more than two countries (typically referred to as a multilateral APA).  This newsletter examines several approaches to achieving a multilateral APA, as well as the key issues to take into account in specific situations.

As the growth of transfer pricing examination and controversy expands around the world, it is increasingly common to find situations in which a multinational enterprise (MNE) group needs to have advance pricing agreements (APAs) with more than two countries.  In such situations, the procedural process can become complex, requiring patience and persistence.  A common situation is reflected in the following illustration.