The Resource APAs : the teenage years

APAs : the teenage years

APAs : the teenage years
APAs : the teenage years
The year in which the APA was born is open to some debate, but 1991 has a good claim. In this year the United States introduced its APA programme and the Apple Computer bilateral APA between the United States and Australia was concluded. The gestation period had been troubled. At the time, a large number of multinationals were thought to be using transfer pricing to divert profits from the United States, and a considerable amount of transfer pricing litigation was under way. Congressional hearings on tax underpayments by U.S. subsidiaries of foreign companies fuelled concerns that such companies were not paying the appropriate amount of U.S. tax. There was a general sense that transfer pricing disputes were too lengthy and expensive, and that the arms length principle was unworkable. The U.S. devised the APA programme with the intention of allowing the IRS and taxpayers to work together in a co-operative rather than contentious manner
Citation source
In: Tax planning international review. - London. - Vol. 34 (2007),
  • Neighbour, J
  • Hickman, A
Geographic coverage
North America
Language note
  • APA
  • transfer pricing
  • arm's length principle
APAs : the teenage years

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