The advance pricing arrangement and the mutual agreement procedure

The advance pricing arrangement (APA) is a tax ruling that provides businesses with legal certainty with respect to their future transactions between two related companies.
The purpose of the mutual agreement procedure (MAP), which is independent of any domestic law remedies, is to resolve situations of double taxation or situations in which taxation is non-compliant with a bilateral tax convention.

The mutual agreement procedure (MAP) is an out-of-court procedure provided for in bilateral tax conventions which aims to eliminate the double taxation of taxpayers. It is independent of any domestic law remedies.

The advance pricing arrangement (APA) is a tax ruling that provides businesses with legal certainty with respect to their future intra-group transactions.