Advance Pricing Agreement

Advance Pricing Agreements ( APAs ) concern in the area of ​​transfer pricing APA procedure between one or more taxpayer and one or more tax administrations.

The tax agreement specifies a method for determining transfer prices for specific transactions for a certain period before the realization of business relationships between associated companies of different countries.

See also paragraph 4.123 of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations of 22 July 2010 and the BMF letter of 5 October 2006: Leaflet for bilateral or multilateral APA procedure on the basis of double taxation agreements to grant mandatory pre- commitments on transfer pricing between internationally affiliated companies (so-called " Advance Pricing Agreements " - APAs ).

Regarding the cost of applying see § 178a AO.

  • Tax and tax law ( Germany )