Types of advance pricing agreements in statutory regulations and the practice of their application

Abstract

Due to its importance and the significance for public finances, the issue of preventing the nega-tive phenomenon of tax avoidance became the subject of an OECD initiative. The aim of this initia-tive was to eliminate, or at least heavily counteract, the increasingly frequent practice of under-taxation and uncontrolled transfer of profits from one country to another. One of the solutions conducive to achieving the indicated goal is the possibility of concluding advance pricing agreements. Advance pricing agreements are also an important solution for taxpayers in this context. The provisions of the act on resolving double taxation disputes and concluding advance pricing agreements indicate three kinds (types) of advance pricing agreements, i.e. unilateral prior pricing agreement, bilateral pricing agreement, multilateral. The practice so far in Poland indicates that the most frequently performed procedure is the issuing of unilateral agreements.