As Crido we offer full range of support in the APA (advance pricing agreement) procedure which is the most effective tool of transfer pricing risk management.

Our support covers also the simplified APA procedure, which is the remedy for limitation on tax deductibility of intra-group service and intangible charges.

Our approach

  • We develop strategies for applying for APA based on the level of complexity of transactions while at the same time seeking to minimize administrative costs of the process,
  • We prepare complete APA applications, taking into account the type of APA procedure, the nature of transactions and the requirements to present the economic justification (the so-called benefit test),
  • We actively support our clients in the APA negotiation process with the tax authorities by moderating preliminary meetings, conducting the official exchange of correspondence, participating in the reconciliation meetings (negotiations) and by monitoring the process.