Advanced pricing agreements APA

Within this scope of our operations, we provide a comprehensive service of the process of making advance pricing agreements (APAs), from the moment the transaction is assessed for the validity of the APA application to the implementation of the administrative decision obtained.

Advance Pricing Arrangements are agreements on the setting of transactional prices between a taxpayer and a competent authority. It is a type of agreement between a taxpayer and a tax authority in which the authority accepts the choice and application of the transaction pricing method used in the taxpayer’s relationship with its affiliates. Such an agreement takes the form of an administrative decision.


The service includes:

  • Detailed analysis of agreements concluded with related parties and recommendations for the conclusion of advance pricing agreements
  • Preliminary meeting at the Ministry of Finance to clarify doubts about the agreement before the formal submission of the application.
  • Preparation of APA applications
  • Representation in the negotiation process with a view to obtaining a decision on the agreement
  • Support in the implementation of APA decisions

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mail: biuro@cmt-advisory.pl