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13.4.4. APAs and Dispute Resolution Mechanisms

Advance Pricing Agreements (APAs)

The revised transfer pricing rules effective from 8 February 2017 provide for the possibility for taxpayers to request an advance agreement concerning their transfer pricing policy from the tax authorities. There is to date, however, no specific guidance on the APA process other than that the taxpayer must approach the tax administration and submit all particulars regarding the relevant transaction. It is thought that the APA process is free of charge.