The requirement in many OECD countries for 'contemporaneous documentation' of a taxpayer's transfer pricing methodologies in order to avoid exposure to substantial penalties has led more taxpayers to consider entering into an Advance Pricing Agreement (APA). To these taxpayers, APAs represent an opportunity to remove the prospect of penalties and other areas of uncertainty related to transfer pricing enforcement. The latest transfer pricing survey by Ernst & Young revealed that '57 per cent of UK subsidiary respondents that have not used APAs would consider using an APA as a controversy management tool in future'.²
² See note in article.
© Copyright Kluwer Law International, 2005
- advance pricing agreement,
- transfer pricing,
- United States
Available at: http://works.bepress.com/michelle_markham/3/