Special Report: Considering and Negotiating an APA

Each year, more countries initiate active transfer pricing enforcement, inevitably increasing the number of transfer pricing disputes. The global inventory of disputes between treaty partners, largely composed of transfer pricing issues, has nearly doubled since 2010, from 3,328 cases to 6,416 cases by the end of 2022. Further, the Organisation for Economic Co-operation and Development (“OECD”) has acknowledged that the BEPS-related changes to transfer pricing, especially the country-by-country reporting (“CbCR”) requirements, have encouraged a large incremental increase in the number of transfer pricing disputes between treaty countries. In the face of such scrutiny, multinational enterprises (“MNEs”) need an approach to ...