Assistance in preparation and negotations of APA application and during the mutual agreement procedure (MAP).
Assistance in obtaining APA and negotations of MAP.
KPMG's services include preparing applications, ongoing contact and conducting negotiations with representatives of the tax administration. On the basis of the granted power of attorney or on the basis of ongoing support and advisory services, KPMG assists its clients, in, among others: obtaining an Advance Pricing Arrangement (the so-called APA); a mutual agreement procedure pursuant to Article 6 of the Arbitration Convention, the European Directive on Double Taxation Dispute Resolution Mechanisms (DRM), or pursuant to a concluded Double Tax Treaty (the so-called MAP procedure).
Moreover, KPMG supports in submitting and obtaining a request for an individual tax law interpretation with respect to the transfer pricing aspects related i.a. transfer pricing adjustments or documentation obligations.
KPMG's activities lead to elimination of the risk of questioning the applied solutions in the scope of settlements with related parties, elimination of double taxation and obtaining greater certainty of the principles of activities conducted by the client.