6. The possibility of extending the provisions of an APA to a period ranging from the first day of the calendar year during which the subject first applied for an APA until the APA came into force if, after reviewing the first application, an APA was refused on the grounds that no agreement was reached between the tax authorities of a foreign counterpart. – on the need to modify the draft APP – the stamp duty of 2 million euros. RUB to re-examine the application for membership of the APP is not perceived – at the conclusion of the APP or – in the event of refusal to conclude the APP, if it is not possible to reach a reciprocal agreement with the competent authority of the foreign state under German law, a pre-price agreement (abbreviated APA) is the combination of a prior agreement between countries regarding the transfer of prices between countries. At the end of the APA, the participating countries determine the method of transfer pricing to be applied for a fixed period in the future between the related companies or certain parts of the companies concerned. This is an administrative procedure based on requirements. Upon receipt of the application, the BZSt verifies that all conditions (including the applicant`s agreement not to challenge the fees) for the execution of an APP procedure are met. An APP procedure is only implemented if the application is admissible and justified. The bill aims to optimize the procedure for concluding advanced price agreements (`APA`) in order to define the conditions under which transactions can be considered controlled and to introduce other specific amendments to the provisions of the Russian tax code.
The appropriate authorities may agree that the subject is required to submit a notification after the APA. The subject may, for example, be required to notify the appropriate authority each year of compliance with the current APA. This reporting obligation is not related to the obligation to provide tax returns or the obligation to provide transfer pricing information, as it relates to a separate notification to the competent authority.