A pre-price agreement (APA) is a prior agreement between a tax payer and a tax authority on an appropriate transfer pricing method (TPM) for a number of transactions involved during a specified period[1] (“covered transactions”). 3. The period during which an APA can be considered must be significantly extended when dealing with foreign tax authorities. The new period is 24 months from the date an application is made. However, this cooling-off period may also be extended to 27 months, but may be suspended for periods during which foreign tax authorities submit documents as part of the DTT`s mutual agreement procedure. Following the signing of the pre-price agreement with the State or foreign countries, BZSt informs the applicant in writing of the result and asks him to approve the content of the agreement. In addition, the applicant is asked to waive his right of appeal to the tax office. Once the applicant has agreed to the content and waived his right of appeal, the tax office grants the applicant the corresponding mandatory prior obligation to implement the pre-transfer prices at the national level. BZSt`s jurisdiction for mutual agreement, arbitration and APAs Proceedings The bill aims to optimise the procedure for concluding advanced price agreements (`APA`), to define the conditions under which transactions can be considered controlled and to introduce other specific amendments to the provisions of the Russian tax code. Under German law, a pre-price agreement (APA) is a combination of a prior agreement between the federal states on the transfer price between internationally linked companies and an expanded obligation based on it.
At the end of the APA, the participating countries determine the method of transfer pricing to be applied for a fixed period in the future between the related companies or certain parts of the companies concerned. This is an administrative procedure based on requirements. A Pre-Pricing Agreement (APA) is a procedural agreement between one or more tax payers and one or more tax authorities, which aims to avoid transfer pricing disputes by pre-defining a set of criteria for certain cross-border controlled transactions within a specified time frame, to ensure that they respect the length-of-arm principle. 6. The possibility of extending the provisions of an APA to a period ranging from the first day of the calendar year during which the subject first applied for an APA until the APA came into force if, after reviewing the first application, an APA was refused on the grounds that no agreement was reached between the tax authorities of a foreign counterpart. Here are the models of applicants` declarations that the applicant must submit to the authorities after the signing of the pre-price agreement. An APA is a contract, usually several years, between a tax payer and at least one tax authority, which indicates the pricing method that the taxpayer will apply to transactions with related companies.