d. The Assessee does not agree with the proposed revision. Does the country have a pre-price program (APA)? If so, is the program widespread? Are there unilateral, bilateral and multilateral APAs? A preferential price agreement or preferential pricing agreement (APA) is an agreement between at least two states parties to a tax agreement. Pre-price agreements are negotiated by the competent authorities of each of the countries concerned. The competent authorities agree on the validity of the APA. An APA is established for a specified period of time and its legal effects extend only up to the validity of the APA. The duration of validity varies from case to case and depends, for example, on factors such as the nature of the transactions involved and the industry. The main advantages of ASAs are minimizing transfer pricing disputes, ensuring legal certainty and easing the calculation of taxes. 1. Review of the agreement [Rule 10-Q]: the agreement may be reviewed by the House (suo motorcycle or at the request of the assessor or the DGIT or the competent authority) in the following circumstances: the validity of an APA is generally five consecutive years or less, as agreed between the subject and the ITA. The provisions of the APA are forward-looking and there is no option to go back.

An APA provides a tool to avoid transfer pricing disputes. The experience of taxpayers and tax authorities with respect to pre-price agreements has shown that the best way to resolve complex transfer pricing issues for all parties is to cooperate before the problem becomes a problem. Finding a solution is usually more difficult. (ii) are not considered to be the expression of the person`s request to enter into an agreement. Roll back rules cannot be used where the ALP`s provision for a given year of return is challenged in the Court of Appeal and the order was made prior to the signing of the contract. In addition, the request for withdrawal reserves is not expected to have an effect on reducing income and loss, as indicated in exchange for the income of the aforementioned year. one. There is a change in the law or facts that affect the agreement.

2. Termination of contract: The contract may be terminated by the House in the following circumstances: the disadvantage of an APA is total transparency and the relatively long time for the conclusion in relation to a transfer pricing study.