The process of obtaining a multilateral APA typically involves the following steps:
Pre-filing Consultation: The taxpayer engages in preliminary discussions with the relevant tax authorities to determine the feasibility and scope of the APA. Formal Application: A detailed application is submitted, outlining the proposed transfer pricing methodology and providing necessary documentation. Review and Negotiation: Tax authorities review the application, engage in discussions, and negotiate the terms of the APA. Agreement and Monitoring: Once an agreement is reached, it is formalized, and the taxpayer must adhere to the agreed terms, with periodic monitoring by the tax authorities.