Legislative changes regarding Advance Pricing Agreements (APAs)
Under the new regulations, taxpayers may request that Advance Pricing Agreements be extended to include similar transactions from previous fiscal periods, with retroactive application possible for up to five fiscal years prior to the year in which the application is submitted. Extension of the validity of APAs is subject to approval by the competent tax authority.
If an application for the issuance or extension of an APA is under review by the competent tax authority while a tax audit is being conducted for the fiscal periods and taxes covered by the application, the tax authority can order the suspension of the tax audit while the application is processed.
