Insights

In this article, we explain how taxpayers could leverage on Advance Pricing Agreements (“APAs”) to guard against the uncertainties of tax compliance in an era of increasingly complex tax rules.

In an ever-increasing integrated global economy, businesses have been establishing their footprints in various locations across the continents. These so-called “multi-national corporations” or “MNCs” have sophisticated supply chains and business platforms comprising of dozens, if not, hundreds of entities, all of which are directly or indirectly related to one another. Under this corporate umbrella, the affiliates would trade and transact with one another.

International taxation is undergoing the biggest shake-up for a generation and the chief driver of this change is the global roll-out of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan.

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Nobody thought that complying with the Base Erosion and Profit Shifting (BEPS) transfer pricing analysis and documentation demands would be easy. Yet, the opening year has proved to make greater demands and has required more attention than many multinational enterprises (MNEs) had anticipated.

The global mobility environment is changing rapidly. Businesses and their employees working internationally are faced with a complex web of regulations and laws. While tax laws change almost daily, wider political agendas and large-scale reforms have the potential to create new complexities and to increase mobility costs.