Advance Pricing Agreement between the tax payer and the tax authority determines, in advance controlled transactions, an appropriate set of methods, comparables and adjustments thereto, critical assumptions as to future events for the determination of transfer pricing for the transactions among the related parties over a fixed period of time. Advance Price Agreements would be unilateral, bilateral or multilateral, and applicable up to 3 years.
General APA procedures are;
• Preliminary Assessment,
• Accept/Reject Case,
• Renewal of APA
• Termination of APA
APA application file includes, but not limited to;
• Functions and risks,
• Price lists,
• Production costs,
• Volume of all transactions and invoicing,
• Financial statements and financial data for the last 3 years,
• Economic assumptions for the future
• Relevant information such as accounting standards, methods,
• Proposed transfer pricing method in details,
• Other relevant documents to determine arm’s length pricing.
GRANIT prepares APA application file including all required analysis and calculations, supervise multinationals and conducts negotiations with the Ministry of Finance.
More information about Transfer Pricing can be found on the Transfer Pricing information site which can be found at;