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Articles

Vol. 125 (2021)

Issuing advance pricing agreement following legislative changes

  • Marek Kopyściański
DOI
https://doi.org/10.19195/0137-1134.125.2
Submitted
December 16, 2021
Published
2021-12-16

Abstract

The procedure for issuing an APA requires the initiative of the taxpayer. It is carried out only at the request of the interested entity. The provisions of the Act on the settlement of double taxation disputes and the conclusion of advance pricing agreements define the content of the application for an APA. The scope of information concerning the applicant and other related entities involved in the controlled transaction covers a number of key issues. Their analysis allows the possible conclusion of an advance pricing agreement. This information is divided into two main groups. The first group includes information on the applicant and other related entities involved in the controlled transaction. The second includes information on the controlled transaction covered by the application.