In times of increasing cross-border transactions, multinational enterprises are faced with the obstacle of rising legal uncertainty and therefore reduced planning reliability in tax matters. Advance pricing agreements (APAs) provide an appropriate means of tackling such problems relating to transfer pricing issues. In the last two decades APAs have risen from relative obscurity to become an important transfer pricing controversy management tool, offering benefits to taxpayers as well as tax administrations. These issues are dealt with in Markham's study, Advance Pricing Agreements - Past, Present and Future, by focusing on the United States and Australia, the two countries that were at the forefront of adopting APAs and whose wealth of experience over two decades confirms their APA programmes as the global paradigms. Markham's study gives the opportunity to further develop the scientific thoughts and apply them to a European context, especially taking into account the practice of Austria.
Intertax