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Countries that currently are developing or enhancing their transfer pricing enforcement should include advance pricing agreements as part of their regimes, a practitioner familiar with both the Canadian and U.S. APA programs advises. “If you're going to step up enforcement, you have to set up the resources to resolve these cases,” Steven Wrappe of Ernst & Young LLP in Washington, D.C., says during the event sponsored by his firm. “You have to allow compliant taxpayers to prove their compliance.” During the webcast, Wrappe, along with Fred O'Riordan and Paul Mulvihill of the firm's office in Ottawa, discuss current challenges facing the APA regimes in both Canada and the United States.
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