Unilateral APA Clause Samples

Unilateral APA. An APA that involves only the taxpayer and the tax authority of the country where the taxpayer is located.

Unilateral APA. A unilateral APA is an arrangement between a taxpayer and a single jurisdiction. Unilateral APAs are solely domestic law instruments of jurisdictions and only provide tax certainty in relation to covered transactions(s) in a single jurisdiction. If issues arise with the counterparty’s competent authority, particularly in cases of potential double taxation, ZATCA is not obliged to defend the APA before the competent authority. In such instances, the taxpayer assumes the risk of double taxation. The taxpayer shall not in any case ask to amend the APA because of any possible adjustments take place from another tax authority.