The results of the ex ante pricing agreement are from the fiscal year preceding the period Throughout the climate that facilitates the process of submitting this transfer pricing agreement, it should help taxpayers to take care of the process. Even for those who are far from the Directorate-General for Taxation, there is no need to do a pre-filling that can take months. Of course, the higher the value of a transaction, the greater the risk. Advance pricing agreements help reduce these risks by providing security guarantees. The transfer pricing agreement is a risk reduction strategy during the negotiation process until its conclusion. Advance Pricing Agreements In addition to “price agreements”, you may also be able to look for explanations on the following terms: this is why more and more countries are now implementing advance pricing agreements. The same is true for Indonesia. The rules will be developed to ensure that the implementation of this transfer pricing agreement is truly effective, such as: the above-mentioned problems cannot be solved simply by the appropriate adjustment mechanism referred to in Article 9(2) or by the mutual agreement procedure (MAGP) provided for in Article 25 of the OECD Model Agreement (OECD model). Advantages of the withholding tax agreement (APA) In addition to legal certainty and the simple calculation of tax, the Treasury is no longer obliged to make corrections when examining the selling price and profits of products sold by taxpayers to companies in the same group. On the basis of the parties involved, apa can be divided into three types (Sawyer, 2004), namely ABS, bilateral and multilateral. The unilateral APA is a binding agreement between a taxable person and a single tax body.

This type is generally not avoided by the tax authorities and does not offer any guarantee to taxpayers in order to avoid double taxation. To advance a price agreement, taxpayers must request the first interviews with the Director General of Taxes. The request is submitted in writing with a neck for the head of the Tax Office of the domicile. Taxpayers and taxpayers from partner countries of several tax avoidance agreements no longer have access to the request for transfer pricing agreements The main definition of ABS is that the APA does not address the issue of pricing, APA only allows the use of transfer pricing methods under acceptable conditions (Burns, 2003).C is why ex ante price agreements are often used by companies that transact with many parties. . . .