Pre-filing Consultation: The taxpayer consults with the tax authority to discuss the potential APA and its terms. Formal Application: A formal application is submitted, detailing the proposed transfer pricing methodology and supporting documentation. Evaluation: The tax authority reviews the application, conducts due diligence, and may request additional information. Negotiation: Both parties negotiate the terms of the APA, including the duration and any specific conditions. Agreement: Once both parties reach an agreement, the APA is finalized and signed.