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...

In the 21st century, the number one international tax issue of interest to multinational enterprises (MNEs) is undoubtedly transfer pricing. The reason for this is that as global trade increases, so too does the uncertainty of the tax treatment of inter-affiliate transactions across national...