Advance Pricing Arrangements (APA)

Advance Pricing Arrangements are formal agreements on setting transaction prices between the taxpayer and the tax authority. As part of the advance pricing agreement, the authority accepts the choice and method of applying the transfer pricing method used in relations between the taxpayer and its related entities. The competent authority for the conclusion of the agreement is the Head of the National Revenue Administration.

A distinction is made between APAs (i) unilateral, (ii) bilateral and (iii) multilateral. The benefits of Advance Pricing Agreements include: protection of the taxpayer against transfer pricing adjustments under the transaction covered by the agreement and no obligation to prepare transfer pricing documentation for transactions covered by the agreement. In addition, bilateral and multilateral agreements additionally give the taxpayer a guarantee of avoiding double taxation, because they mean confirmation of the correctness of the applicable terms of transactions between related parties not only by the competent authority of the Republic of Poland, but also by the competent authorities of the countries where the entities with which the taxpayer concludes transactions .

PKF specialists will guide you through the entire procedure of obtaining an APA, starting from contacting the National Revenue Administration, through preparation of the necessary materials for submitting the application, support in submitting appropriate explanations to KAS questions, and ending with the issuance of the above-mentioned documents. decision.

We provide Transfer pricing and other services throughout Poland in regional offices in Warsaw, Łódź and Poznań, Opole, Wrocław, Katowice, Lublin, Gdańsk and Zielona Góra.