Advance Pricing Agreements


Example Advance Pricing Agreement (APA) analyses include:

  • Analysis of arm’s-length buying agency commission rates for a US retailer’s procurement operations in Asia; submitted to IRS in a successful APA request.
  • License royalties for optical implant technology; submitted as part of an APA request.
  • Intercompany management and IT services transactions for a US-France bilateral APA.
  • Distribution services and arm’s-length margins for a successful US-Canada bilateral APA.
  • Various analyses in support of global manufacturers’ compliance with APAs with the Mexican taxing authorities.