Here you will find the sample applicants` declarations that the applicant must submit to the authorities after signing the advance settlement agreement. The applicant shall determine the content of the PA in his application. The application must define the scope of application, both in time and in substance. In addition, mention should be made of other countries that require advance pricing reporting. When an applicant requests a multilateral ABS (with more than two participating states), the PA consists of several bilateral ABS. Therefore, the ABS procedure is particularly appropriate for situations where the parties need to agree on key transfer pricing issues, which are free to interpret. Before submitting an application for an APA, the taxpayer should have a prior interview with the competent authority to determine whether the ABS procedure is appropriate for the transfer pricing case of the taxable person. The purpose of the preliminary interviews is to choose, in each case, the most appropriate procedure. Yes, the APA programme is independent of the audit function of the tax administration and the competent authorities that deal with other cases of double taxation. All the taxable person`s documents are returned to the taxable person if the taxable person`s ABS application is not approved or cancelled by the DGT. No documentation during the APA process may be used by DGT for tax audit and investigation purposes.

Posted by / september 8, 2021
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