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Transfer Pricing5 min read
The FTA's APA programme — who should apply, and when
The Advance Pricing Agreement programme offers 3–5 years of certainty. Whether it's right for you depends on your transaction profile.
The FTA's newly launched Advance Pricing Agreement (APA) programme — covering both unilateral and bilateral agreements — lets taxpayers agree a transfer pricing methodology with the authority in advance, securing certainty for three to five years.
Good candidates for an APA
- High-value, recurring related-party transactions.
- Structures where audit exposure would be material and disruptive.
- Groups seeking certainty ahead of a transaction or restructuring.
An APA is not free of effort — it requires a robust functional analysis and benchmarking — but for the right profile it converts years of uncertainty into a known, agreed position.