Advance Pricing Agreements – characteristics in Central and Eastern Europe | Infographic

Unilateral APA – CZK 10,000 for one transaction (approx. EUR 400)

Depending on the number of jurisdictions taking part in the APA, filing fees vary as follows:

Unilateral APA – HUF 2,000,000 (approx. EUR 6,210)

Bilateral APA – HUF 4,000,000 (approx. EUR 12,420)

Multilateral APA – HUF 2,000,000 (approx. EUR 6,210) per participant jurisdiction

In the case of proceedings for APA extension or modification, the fee is 50 percent of the fee paid in the original procedure. If the APA request is rejected or withdrawn, the HTA returns 85 percent of the fee already paid pertaining to the APA procedure. The pre-filing consultation is subject to an administrative fee. The fee for a pre-filing consultation is HUF500,000 (approx. USD1,780) per each consultation.

1% of the value of the transaction that is the object of the agreement. However, in the case of:

Unilateral APA:

• concerning domestic entities – min. PLN 5,000 (approx. EUR 1,165) and max. PLN 50,000 (approx. EUR 11,647)
• concerning foreign entity – min. PLN 20,000 (approx. EUR 4,659) and max. PLN 100,000 (approx. EUR 23,294)

Bilateral or multilateral APA – min. PLN 50,000 (approx. EUR 11,647 ) and max. 200,000 PLN (approx. 46,589 EUR)

Simplified APA – the Polish Ministry of Finance is working on bill introducing simplified APA procedure for some transactions. The project assumes that it can be applied for low value-added services and for paying fees for using or the right to use the trademark or knowledge / information constituting know-how. Simplified APA will be issued within 3 months for a period of 3 years with possibility of extension for another 3 years. The cost of issuing will be probably around PLN 20.000 (approx. EUR 4,659). Expected date of entry into force is the third quarter of 2019.

For large taxpayers and other taxpayers with consolidated value of transactions higher than EUR 4,000,000:

• EUR 20,000 for the initial APA
• EUR 15,000 for amending the initial APA

For other taxpayers and consolidated value of transactions lower than EUR 4,000,000:

• EUR 10,000 for the initial APA
  EUR 6,000 for amending the initial APA

Unilateral APA – EUR 10 000

Bilateral and multilateral APA – EUR 30 000