There are a few factors that are problematic during the AAS agreement with the DGT: an overview of the new provisions of the Senegalese tax law on transfer prices. The German tax authorities regularly conclude bilateral and multilateral APAs (unilateral decisions on transfer pricing with effect in the future are granted only in exceptional circumstances). AAPas are an increasingly widely used tool: 56 APP requests were sent to German tax authorities in 2018 and 43 bilateral and multilateral APAs are in effect according to the EU Joint Forum on Transfer Prices at the end of 2018. The Russian Ministry of Finance publishes the regulation approving the procedure for concluding prior pricing agreements with russian and foreign tax authorities In principle, any transfer pricing case involving internationally related parties may be covered by an APP. The details of the specific case are usually discussed at the pre-notification meeting. One. Preliminary interviews (on the basis of a relevant application in any form) on the assessment of the existence of the reasons for the conclusion of an APA, the pricing procedure and/or the application of the pricing procedures proposed by the subject, the procedure and timetable for the conclusion of the APP, the prospects for mutual agreement between the competent authorities and their implementation in the Federation. 5. Conclusion of the APA: at this stage, the subject must inform the FTT of his consent (disagreement) with the FTT decision in a manner that he chooses.
If such a notification is not made within 30 days of receiving the decision, the subject is deemed to disagree with the decision. After the APA takes effect (which also requires the agreement of the subject and the waiver of the right of appeal) and at the request of the subject, the local tax authority must make a binding decision reflecting the agreement reached in the APA. The main advantage of an APA is the creation of planning and legal certainty with respect to transfer pricing issues, which avoid future (expensive) conflicts, simplify future processes and audits, and avoid the interest rate in the event of late payment.