Advance Pricing AgreementsAdvance Pricing Agreement • September 9th, 2009
Contract Type FiledSeptember 9th, 2009The amendment of June 30, 2005 of Tax Ordinance, allows for the possibility to enter into so-called advance pricing agreements (“APA”). This procedure permits taxpayers to enter into agreements with tax authorities on the application of the method of determining prices in related party transactions. Such agreements include on the taxpayer’s request provisions interpreting tax law, whereby the tax authorities acknowledge the correctness of a particular method of transfer pricing. The provisions on APA came into force on January 1, 2006.