Advance pricing agreements

Overview

An Advance Pricing Agreement (APA) is an agreement entered into between tax authorities and taxpayers on the future application of transfer pricing policies.  An APA can be an effective measure for many taxpayers in mitigating transfer pricing risks by ensuring levels of future profitability are accepted as reasonable by the tax authorities.

Since the inception of the APA programme in Vietnam AA have been involved in the negotiation of a large number of cases, helping companies reduce uncertainty by negotiating APAs with tax authorities in Vietnam and overseas. 

How we can help

• Developing robust technical arguments to support unilateral, bilateral and multilateral APA submissions;
• Drafting and submitting APA applications; and
• Liaising with the GDT, including answering questions and negotiating to obtain the APA.