Advanced Pricing Agreement Po Polsku

Critical assumptions are essential for ABS and should be carefully developed to ensure that ABS is able to reflect subcontracting prices. An advance pricing agreement (APA) is a procedural agreement between one or more taxable persons and one or more tax authorities, which aims to avoid transfer pricing disputes by defining in advance a number of criteria applicable to certain cross-border transactions controlled within a specified period of time, in order to ensure that they comply with the at-its-view principle. 2. In order to find pragmatic solutions to this problem, the Commission set up the EU Common Transfer Pricing Forum (JTPF) in October 2002. In two communications, the Commission reported twice on the work of the JTPF. The first communication[1] presented a code of conduct[2] on the Double Taxation Convention (hereinafter referred to as “the Arbitration Convention[3]” in order to ensure a more efficient functioning of the Convention. . . .