One. Preliminary interviews (on the basis of a relevant application in any form) on the assessment of the existence of the reasons for the conclusion of an APA, the pricing procedure and/or the application of the pricing procedures proposed by the subject, the procedure and timetable for the conclusion of the APP, the prospects for mutual agreement between the competent authorities and their implementation in the Federation. Upon receipt of the application, the BZSt verifies that all conditions (including the applicant`s agreement not to challenge the fees) for the execution of an APP procedure are met. An APP procedure is only implemented if the application is admissible and justified. The Russian Ministry of Finance publishes the regulation approving the procedure for concluding prior pricing agreements with the Russian and foreign tax authorities In accordance with the regulation, the procedure for concluding a prior price agreement (“APA”) contains the following features: a prior price agreement (APA) is an agreement between the tax authorities and taxpayers on the future application of the transfer pricing policy. An APA can be an effective measure to reduce transfer pricing risks for many tax payers, ensuring that the level of future profitability is accepted as appropriate by the tax authorities. 5. Conclusion of the APA: at this stage, the subject must inform the FTT of his consent (disagreement) with the FTT decision in a manner that he chooses. If such a notification is not made within 30 days of receiving the decision, the subject is deemed to disagree with the decision. The regulation aims to fill the legal void resulting from the absence of a formal procedure for concluding pre-price agreements for cross-border transactions with foreign tax authorities and to encourage taxpayers to use this instrument. The double taxation agreement is available on the website of the Federal Ministry of Finance. The main benefits of an APA include: – the prevention of tax controls for APA-covered transactions (reducing costs and related efforts) and eliminating any transfer pricing adjustments: – removal of late interest and penalties for possible transfer pricing adjustments; Eliminating the costs of establishing the transfer pricing record for APA-covered transactions (during the period during which the APA is in effect); Avoid double taxation. Taxpayers work in an increasingly regulated business environment, where transparency is essential.
Taxpayers need a certain degree of security in managing their tax and potential exposure to risk. Pre-price agreements (APAs) help provide this security to taxpayers. 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 (“covered transactions”). An APA is a solution for taxpayers seeking maximum security in compensation prices for future years. Our transfer pricing professionals can facilitate and support the entire APA process: the APA aims to determine the tax debt between two or more states for a specified future period. The partners in the advanced transfer pricing procedure are therefore the contracting states concerned. However, the applicant is regularly informed of the status of the procedure and the status of the procedure. Companies that wish to avoid the threat of double economic taxation in advance can apply for an APA.