Mitigating risk through bilateral APA

A financial institution wanted to mitigate its risk of double taxation, in a high risk country, through the application of an advance pricing agreement (APA).

The tax considerations involved managing the past years which the financial institution had operated in the country through understanding the detailed facts and housekeeping before involving the competent authorities in any country.

Also, several considerations were made to accommodate the interest of both competent authorities and the potential political aspects involved.