An Advance Pricing Agreement (APA) is an agreement between a taxpayer and a tax administrator that aims to avoid any transfer pricing disputes, by determining the arm’s length price for a controlled transaction.
Our infographic “Advance pricing agreements” is a sum-up of characteristics of APA in Czech Republic, Hungary, Poland, Romania and Slovakia.
Czech Republic
Maximum initial duration*
Possibility of extension if legal conditions remain unchanged
Hungary
Maximum initial duration
Possibility of extension if legal conditions remain unchanged
Poland
Maximum initial duration
Possibility of extension if legal conditions remain unchanged
Romania
Maximum initial duration
Possibility of extension if legal conditions remain unchanged**
Slovakia
Maximum initial duration
Possibility of extension if all conditions remain unchanged
Application responsibility: The tax administrator issues the APA on the basis of an application filed by the taxpayer. In other words, the tax administrator cannot issue the APA “ex officio”.
Language options: The application for the APA, to which the TPD shall be enclosed, too, must be filed in local language only*.
*except Hungary (where English, French, and German languages are also accepted) and Slovakia (where upon request the tax authority may agree with other language for the TPD)
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