Advance Pricing Agreement
Advance Pricing Agreements ( APA s) are agreements in the area of transfer pricing between one or more taxpayers and one or more tax administrations.
The tax agreement lays down a method for determining transfer prices for certain business transactions for a certain period of time before business relationships are established between affiliated companies of different countries.
See also Item 4.123 of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations of July 22, 2010 as well as the BMF letter of October 5, 2006: Information sheet for bilateral or multilateral advance agreement procedures on the basis of double taxation agreements for the issuing of binding advance agreements on transfer prices between internationally affiliated companies (so-called "advance pricing agreements" - APAs) .
In Germany, the costs for the application are regulated by § 178a AO .
As became known from the Luxembourg leaks , the number of advance transfer pricing commitments rose within two years from 119 to 519 in Luxembourg since 2013 and from ten to 411 in Belgium over the same period.
Individual evidence
- ↑ http://www.oecd.org/tax/transfer-pricing/transfer-pricing-guidelines.htm
- ↑ http://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Internationales_Steuerrecht/Allgemeine_Informationen/2006-10-05-Merkblatt-APA.html
- ↑ The number of tax deals in the EU is increasing massively , Spiegel online, December 7, 2016. Accessed December 7, 2016.
