Transfer Pricing. Advance Pricing Agreements Bob Ackerman John Michaelson. Transfer Pricing Disputes. Factually intensive Frequently contentious and controversial Time consuming Adversarial Arbitrary resolutions Expensive from both taxpayerâ€™s and taxing authorityâ€™s perspective.
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Advance Pricing Agreements
1. To arrive at an understanding on three basic issues
2. To do so in an environment that encourages common understanding and cooperation
3. To come to an agreement in an expedited fashion
4. To come to an agreement in a cost effective fashion