RegulatorySample

APA secured in 18 months for a technology group

We helped a captive technology services provider obtain an Advance Pricing Agreement, removing years of transfer-pricing uncertainty.

ADA International Tax Desk28 Jan 20261 min readInternational Tax & Transfer Pricing

Article image

Challenge. A captive technology centre faced repeated transfer-pricing adjustments on its cost-plus margin, creating uncertainty and litigation cost.

Approach. We prepared the APA application, benchmarked the margin, engaged with the APA authority, and negotiated a defensible arm's-length range with a rollback.

Outcome. A unilateral APA was concluded in about 18 months, giving the group multi-year certainty and ending repetitive disputes.

Illustrative and anonymised. Timelines vary with facts and authority workload.

APATransfer PricingTechnologyGCC

Related insights

Regulatory

Reduced effective tax rate by 8% on a cross-border pharma acquisition

How we restructured a pharma group's acquisition holding chain to optimise effective tax rate while staying fully FEMA- and treaty-compliant.

12 Mar 2026

Regulatory

Pillar Two is here: what large Indian groups should do now

With the global minimum tax operative across major jurisdictions, in-scope Indian groups need to model their effective tax rate jurisdiction by jurisdiction.

28 Apr 2026

Regulatory

$10M raised after a fractional-CFO engagement with a D2C brand

A consumer brand brought us in for MIS and fundraising readiness; within two quarters it closed a growth round on clean, investor-ready numbers.

15 Dec 2025

Work with ADA

Ready to talk to an advisor?

Book a consultation and get a clear, considered view from a team that handles audit, tax, regulatory and cross-border work under one roof.

Get Your Free Tax Health Check — Book a 30-Min Consultation Talk to an Expert