Abstract
Transfer Pricing Issues remain at the forefront of tax planning issues for multinational enterprises (MNEs). Whereas previously transfer pricing was seen as a means to procure a tax benefit, MNEs are increasingly adopting a more conservative attitude towards transfer prices issues. This has meant that MNEs are increasingly seeking to enter into advance pricing arrangements (APAs) with the relevant tax authorities to prospectively determine their tax liabilities. The author analyzes the benefits of APAs in this context, specifically how they confer greater certainty in respect to transfer pricing issues. It is argued that APAs are not suitable for all participants. Part of the reason is that tax authorities have been less than accommodating in allowing MNEs to access their APA programmes.
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