The process of obtaining a unilateral APA typically involves the following steps:
Pre-filing Consultation: Initial discussions between the taxpayer and the tax authority to determine the suitability of an APA. Formal Application: Submission of a detailed application, including information on the proposed transfer pricing methodologies and relevant financial data. Review and Negotiation: The tax authority reviews the application and may request additional information or suggest modifications. Agreement: Once both parties agree, the APA is formalized and becomes binding.