The negotiation process typically involves the following steps:
Pre-filing Meeting: Initial discussions between the taxpayer and the tax authority to understand the nature of the transactions and the need for an APA. Formal Application: Submission of a detailed application that includes information about the business, related transactions, and the proposed transfer pricing method. Evaluation: The tax authority evaluates the application, which may involve discussions, additional documentation, and site visits. Negotiation: Both parties negotiate the terms and conditions of the APA, including the transfer pricing method and the duration of the agreement. Agreement: Once both parties agree, the APA is formalized and signed.