In accordance with the decision of the Council of Ministers, information and exchange of ideas with the taxpayer should be carried out at each stage of the pre-price agreement. On the other hand, any agreement is specific only to the taxpayer associated with it and concerns that taxpayer. It is therefore impossible to use these agreements in other transactions as precedents or as proof of transaction. China – It is one of the countries in its own right in the world of transfer pricing. The method of implementing the APA in China seems almost the same as in the United States, with a preparatory phase, a formal application phase, a review and evaluation phase, a negotiation phase, a final phase. Until now, most PAAs have been unilateral, with APAs affecting several jurisdictions in China, five bilateral APAs completed, with 2 with Japan, one with the United States and 2 with Korea.26 United Kingdom – The United Kingdom has had formal APP procedures since 1999. The UK APP method is only used to solve complex transfer pricing problems or, alternatively, when distinguishing the strategy to be applied in the application of the arm length principle. APA may include transfer evaluation strategies that include different types of transactions with related parties or for certain forms of transactions, as well as being intragroup alternative agreements, as well as physical or immaterial transfers, as well as in service delivery. “Advance Pricing Agreement” is an agreement between a tax payer and a tax authority on an appropriate transfer pricing method for a number of transactions over a period of time in the future. The APA provides better coverage of transfer pricing methods and promotes security and unanimity of the approach. Some countries allow unilateral agreements for which the tax administration and the taxpayer meet and reach an agreement.
However, a unilateral APA can affect the tax debt of associated companies in other tax areas. Where unilateral APAs are permitted, the competent authorities of other relevant jurisdictions should have the opportunity to determine whether they are willing and able to consider a bilateral agreement as part of the mutual agreement procedure.