Competence of the BZSt in matters of mutual agreement procedures, arbitration and APAs The applicant determines in his application the content of the APA. The application must define the scope of application, both in time and in substance. In addition, mention should be made of other countries that require advance pricing reporting. When an applicant requests a multilateral ABS (with more than two participating states), the PA consists of several bilateral ABS. Under German law, an advance pricing agreement (APA) is the combination of a prior agreement between countries on transfer pricing between internationally related companies and a pre-award based on it. When concluding APAs, participating countries shall define the transfer pricing method to be applied between undertakings or related parties for a specified period. This is an administrative procedure based on applications. Taxpayers can also request the Spanish tax authorities to submit the proposal to the tax authorities of other countries where tax companies are established in order to conclude an agreement between the different tax services and therefore to evaluate all the tax parties – related. 3. The period during which an ABS may be considered should be considerably extended in the case of foreign trade transactions involving foreign tax authorities. The new period is 24 months from the date of adoption of an application. However, this cooling-off period may also be extended to 27 months, but may be suspended for periods during which foreign tax documents are provided as part of the DTT cartel procedure. The APA is used to define the tax liability between two or more states for a given future period.
Interested parties are therefore parties to the advanced transfer pricing process. However, the applicant shall be regularly informed of the progress of the procedure. 2. Allow the taxable person to conclude a unilateral ABS if, after examination of a draft APA, the Russian and foreign tax authorities do not reach a mutual agreement. Upon receipt of the application, the BZSt verifies that all conditions (including the applicant`s agreement not to contest the fees) are met for the implementation of an PA procedure. An APA procedure shall only be implemented if the request is admissible and reasoned. These agreements allow taxable persons to avoid future transfer pricing disputes with the Spanish tax authorities and become an effective alternative to the traditional tax audit process. .
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