Number of APAs in 2022 at similar level to previous year
Traders entered into 98 advance pricing agreements (APAs) with the Minister of Finance in 2022. This is three fewer than in 2021, according to the latest statistics from the Ministry of Finance.
The largest number of agreements was unilateral – 96. Exactly the same number was concluded in 2021. There were 2 bilateral agreements last year (5 in 2021). Again, entrepreneurs did not conclude any multilateral agreement.
– The MF statistic confirms that entrepreneurs have practically started to use the prior price agreement tool more frequently since 2021. In 2020, only 18 such agreements were concluded, and a year later, there were already 101. The ministerial data also show that there are a further 340 agreement proceedings pending (288 unilateral, 51 – bilateral and 1 multilateral), notes Cyprian Werykowski, tax adviser, director at Thedy & Partners.
What other information emerges from the published data? Well, the most common method of pricing in concluded agreements is the net transaction margin method. In turn, the most common type of transaction is the purchase of services by a domestic entity.