Advance Pricing Agreement Statistics

16.09.2019 – The first day of the OECD tax took place today at the OECD headquarters in Paris. As G20 ministers recognized, maintaining and improving tax security benefits taxpayers as well as tax administrations and is key to promoting investment, jobs and growth. This is particularly true in the context of the rapid digitalisation of the economy, the emergence of new business models, increasing internationalisation, which is putting pressure on audit practices and stimulating changes in international tax legislation. Improving tax security is one of the main priorities of the OECD Tax Administration Forum, which brings together 53 advanced and emerging tax administrations. Upon receipt of the application, the BZSt verifies that all conditions (including the applicant`s agreement not to contest the fees) are met for the implementation of an PA procedure. An APA procedure shall only be implemented if the request is admissible and reasoned. The statistical report focuses only on LDCs between EU Member States and not on third countries. The APA is used to define the tax liability between two or more states for a given future period. Interested parties are therefore parties to the advanced transfer pricing process. However, the applicant shall be regularly informed of the progress of the procedure.

The applicant shall determine the content of the PA in his application. The application must define the scope of application, both in time and in substance. In addition, mention should be made of other countries that require advance pricing reporting. When an applicant requests a multilateral ABS (with more than two participating states), the PA consists of several bilateral ABS. Factsheet on pre-contractual bilateral or multilateral procedures In July 2019, the European Commission published statistics on pending pre-jurisdiction agreements (ABS) and mutual agreement procedures (POPs) for 2018. Tax Security Day brought together more than 200 tax policy makers, tax administrations, business representatives and other stakeholders from more than 50 countries. They took stock of the status of the tax security program and discussed ways to further improve dispute resolution and dispute resolution. Discussions focused on all tax instruments available to tax administrations, including cooperative compliance programmes, pre-jurisdiction agreements, the International Compliance Assurance Programme (ICAP), joint audit and the cartel procedure (MAP). On Tax Security Day, France also joined the ICAP pilot project, bringing the total number of tax administrations participating in the ICAP pilot project to 18. The meeting highlighted the relevance of the oecd`s recent report on tax morale.

The report examines the latest information on the importance of tax security as a determinant of companies` willingness to participate positively in the tax system, particularly in developing countries. .

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