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APA - Advance Pricing Agreement


An Advance Pricing Agreement, or APA for short, is an administrative decision in which tax authorities conclude that the transfer pricing applied in a transaction with an associated enterprise it at arm’s length.


Advance Pricing Agreements have been present in Polish law since 2006, however, they were not very popular among taxpayers at the beginning. The Act on Resolving Double Taxation Disputes and Concluding Advance Pricing Agreements introduced as of 29 November 2019 new regulations on concluding APAs. Statistics published by the Ministry of Finance show an increase in the number of APA applications filed. This results from the fact that taxpayers are becoming more and more aware of the advantages of that solution.


Under APA, the total expenditures incurred for performing a given transaction are tax-deductible, regardless of the limit set in Article 15e of the Polish CIT Act. Furthermore, the taxpayer is exempt from the obligation to prepare transfer pricing documentation for the transactions covered by the APA.


With the legislative changes and the rising interest in APA in mind, please find below a list of articles authored by Rödl & Partner experts. There you can find out more about the advantages of APAs and see the latest APA-related statistics.


Advance Pricing Agreement forms: APA-P and APA-C »

Advance Pricing Agreements (APAs) are getting more popular in reaching an understanding with tax authorities as to the correct transfer pricing method in transactions with associated enterprises.


One APA to cover the taxpayer’s entire business? »

If you enter into an Advance Pricing Agreement (APA) in respect of one controlled transaction, you obtain measurable benefits in respect of that one transaction only.

APA from international perspective »

Many countries have added to their tax codes far-reaching and very strict regulations to prevent tax-avoidance strategies, at least since the OECD passed the BEPS Action Plan in 2015.


APA procedure in practice »

An Advance Pricing Agreement (APA) is concluded between a tax authority (or authorities – in the case of bilateral or multilateral APAs) and the taxpayer applying for the APA.


Cooperative compliance agreement instead of APA? »

The Polish Tax Act was amended with effect from 1 July 2020 to include provisions enabling taxpayers to sign a cooperative compliance agreement.


APA application procedure – step by step »

Taxpayers are increasingly interested in Advanced Pricing Agreements (APA). The application procedure for an APA consists of several stages.


APA popularity »

Taxpayers who carry out controlled transactions with associated enterprises are applying more and more often to the Head of the National Revenue Administration for Advance Pricing Agreements (APAs).


What in the APA for a taxpayer? »

An Advance Pricing Agreement (APA) can sometimes bring a number of benefits to a taxpayer. Above all, an APA ensures tax-deductibility of certain expenses above the statutory limit.


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Joanna Tomczak

Tax adviser (Poland)

Senior Associate

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Dominika Tyczka-Szyda

Tax adviser (Poland)


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