SAT simplifies procedure for unilateral APA
On 30 July 2021, the State Administration of Taxation (SAT) announced Notice [2021] No. 24, on “Matters Regarding Application of the Simplified Procedures for Unilateral Advance Pricing Arrangements”. This notice simplifies the negotiation and signing process between taxpayer and tax authority and specifies the time limit for application acceptance.
The simplified procedures now consist of only three phases comprised of 1) evaluation of application; 2) negotiation and signing; 3) monitoring and execution. The requirements for a pre-filing meeting, intention for an APA, and analyses and evaluation have been removed.
The simplified procedures set time limits for tax authorities on the acceptance of APA applications and on the negotiation and signing. Tax authorities must send a Notice on Tax Matters to the submitting enterprise within 90 days of receiving the APA application to inform the enterprise of whether or not the application has been accepted, and negotiation and signing must be completed within six months.