The Pre-pricing Program (APA) is an important part of our compliance assurance strategy. The AAAs offer you the opportunity to reach an agreement with us on the future application of the principle of arm length to your relations with international relatives. Download our transfer pricing brochure for details from July 1, 2016, Revenue has set up an official bilateral APA program. The introduction and publication of this official revenue programme provides taxpayers with clarification of both: in addition to the establishment of a clearer mechanism for monitoring compliance with transfer pricing rules for cross-border transactions, including through the conclusion of pre-price agreements, mainly bilateral and multilateral. , the bill encourages the adoption of rules for the implementation of mutual agreement procedures. These rules provide the necessary framework for the relevant Russian authorities to cooperate with their foreign counterparties, both on transfer pricing and other international tax matters. This opens up wide opportunities for Russian taxpayers to be transparent and predictive in the tax treatment of cross-border transactions and to eliminate double taxation through dialogue with the relevant tax authorities of the states concerned. The appendix begins with the definition of the different types of APA and describes the objectives of the APA process. The ability to participate in an APA MAP is considered with respect to contractual issues and other factors such as the audit status of the subject. Issues relating to multilateral GPAs (i.e., where there is more than one bilateral agreement) are also addressed. The central point of the annex deals in detail with the whole MAP-APA procedure, starting with the meetings before the presentation, on the presentation of a proposal, its evaluation by the tax authorities, the discussion and conclusion of the mutual agreement, the implementation of this mutual agreement and, finally, the follow-up of the agreement and a possible extension. While the Schedule focuses on the direction of tax authorities, it takes the opportunity to discuss how the taxpayer can best contribute to this process.
In October 1999, the OECD published an update of the OECD guidelines on clearing prices for multinational companies and tax administrations in 1995 (the so-called “guidelines”). This update takes the form of a new schedule to the guidelines, which contains guidelines for the implementation of ex ante price agreements as part of the Mutual Agreement Procedure (MAP-APAs). The annex is an integral part of the guidelines, as evidenced by the OECD Council`s decision of 28 October to amend its original recommendation on the 1995 guidelines to include the new guidelines in this annex. It therefore has the same status as the eight existing chapters of the guidelines. Typically, a bilateral APA is a binding agreement between two tax administrations and the taxpayers concerned. This agreement is concluded by referring to the corresponding double taxation agreement. It regulates the tax treatment of future transactions between related subjects.