Advance Pricing Agreements

Advance Pricing Agreements

Transfer Pricing

Charles River Associates was engaged by a multinational pharmaceutical firm to assist in the preparation and negotiation of a series of unilateral and bilateral APAs covering distribution, research and development, marketing, and management support functions simultaneously across a number of jurisdictions, including US, UK, Canada, Germany, France, and Spain.

As a part of this project, we:

  • Tested and developed various economic methodologies to establish a favorable and defensible position for the client;
  • Prepared APA submission reports setting out the economic analysis used to support the client’s position in each jurisdiction;
  • Anticipated and responded to a series of inquiries and data requests issued by the tax authorities;
  • Reviewed the position papers prepared by the tax authorities, addressing their positions and arguments; and
  • Assisted our client in preparing annual reports that demonstrated compliance with the terms and conditions of the APAs and are supporting the renewal process as the original agreements expire.