eu joint transfer pricing forum - European Commission

Mar 8, 2018 - Statistics on APAs in the EU at the End of 2016 ..... different countries (for example service centre in Poland). ... columns 1 and 2: The UK does not record all data in the same format as has been requested by the EUJTPF.
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EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION Direct taxation, Tax Coordination, Economic Analysis and Evaluation Direct Tax Policy and Cooperation

Brussels, March 2018 Taxud/D2 DOC: JTPF/015/2016/EN

EU JOINT TRANSFER PRICING FORUM Statistics on APAs in the EU at the End of 2016

Meeting of 8 March 2018

1

What types of Advance Pricing Agreement (APA) options are available?

MS

Is there a filing fee for APA requests?

Total Number of Total Number of Total Number of Bilateral and Number of APA Unilateral APAs in APAs in force at Multilateral APAs in requests received force at the end of the end of 2016 force at the end of in 2016 2016 2016 EU

Austria

Unilateral (Advance rulings); Bilateral; Multilateral

(i)

For unilateral yes, for bilateral/multilateral - no

-

-

655

440

8

6

647

434

45

10

1

-

44

10

3

9

3

9

-

-

Advance rulings (unilateral APA), Yes (unilateral only) bilateral and multilateral APA's.

23

27

3

2

20

Unilateral; Bilateral; Multilateral

No

17

34

10

26

7

Bilateral; Multilateral (Unilateral rulings on transfer pricing are only available under exceptional circumstances specified in a 2006 Federal Ministry of Finance circular)

Yes Generally: EUR 20 000 (15 000 for prolongation/10.000 for amendment); Smaller enterprises: EUR 10 000 (7 500/5 000); In case of hardship and specific interest of tax administration in APA: 0 €

No

Croatia

APA's or advance rulings are available since the middle of 2016 but there are no cases initiated since then

Cyprus

APAs are not available. Advance rulings on the interpretation/application of the tax laws are available on request

Czech Republic

Unilateral (Advance rulings legislation from 1st of January 2006); Bilateral and Multilateral (possible under MAP)

Yes CZK 10 000

Bilateral, Multilateral, Advance rulings

Yes Only for Advance Rulings; the filing fee is DKK 300.

France

Germany

Greece

NON-EU

1

No regulations available at this moment

Finland

EU

1

Bulgaria

Estonia

NON-EU

1

Unilateral (Advance rulings); Bilateral; Multilateral

Denmark

EU

1

Belgium

(ii)

NON-EU

EU

NON-EU

465

20 1)

217

2 1)

Number of APAs granted in 2016

EU

NON-EU 1

1

635

433

18

Number of APA applications rejected in 2016

EU

NON-EU

Number of APA applications where Average time in months to the taxpayer negotiate bi- or multilateral withdrew its APAs request in 2016 EU

NON-EU

EU

NON-EU 46

51

-

-

-

-

29

34

-

1

4

1

-

-

-

1

-

-

1

15

20

-

-

-

-

61

19

5

1

6

1

23

26