APA Procedure: a tool for efficient tax risk management in new transfer pricing realities

While analysing the attractiveness of Advance Pricing Agreements (APA) through the prism of the number of applications submitted in the past, it was easy to conclude that this instrument was rather exclusive. However, our recent observation is that Advance Pricing Agreements have become more popular, and specifically the period 1 December 2018 - 31 January 2019 saw a dramatic increase in the number of APA applications. The abundance of benefits of APA motivated us to make an additional attempt to make it popular.

About the report

The main goal of this report is to present the stages of the APA procedure and to make a statistical comparison of the current picture of the national APA procedure with historical data and practices of other countries. The report also provides a detailed description of the procedure regarding the projected rules for entering into a simplified pricing agreement (sAPA). Statistical parts are based on the data received from the Ministry of Finance in replies to requests for public information.

The report provides information on:

inspection statistics,
transfer pricing areas of special interest,
benefits of an APA decision,
APA procedure,
stages of the APA procedure,
polish APA procedure against the background of some other EU member states,
popularity of the APA procedure,
changes in the current APA procedure,
main assumptions of the new type of advance pricing agreements: simplified pricing agreements (sAPA),
scope of protection afforded by an APA/sAPA,
sAPA summary.

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