The future for multinational group includes increased disclosure, complexity and controversy therefore APAs are increasingly attractive, but the global tax environment is changing and has implications for taxpayers and tax authorities.
Furthermore, Mutual Agreement Procedure (MAP) cases are on the rise and therefore APAs ought to be increasingly popular. However the global tax environment has changed drastically,with the EU State Aid investigations, negative press on ruling practices generally, increased APA disclosure requirements and capacity constraints within tax authorities all combining to inhibited their growth, particularly in Europe.
This article discusses the changing landscape for APAs, outlining what taxpayers can expect going forward and what they should consider if they are anticipating entering into an APA.
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