Details on the introduction of Advance Pricing Arrangements (APAs) are now available in the Official Gazette on 28 December 2016. Accordingly, the following rules will apply from January 2017:
(i) The application of APA must be addressed to the financial administration and must contain mandatory elements and an indication of the type of APA (i.e. unilateral, bilateral or multilateral); (ii) Serious assumptions must be described and be in accordance with the arm’s length principle; (iii) An APA may be signed for 5 years with the possibility of an extension; (iv) If the circumstances of the APA change, the taxpayer or tax authorities may request its termination; (v) A request for an extension must be filed at least 6 months before the validity of the APA has elapsed; and (vi) The cost of an APA procedure is EUR 15,000.
