Part 1 - AL-Tax

income taxation tax authorities’ taxation for the taxpayer’s correctnessprocessof self-assessmentType of Request versus ‘Request’ for APA process ‘Application’ for APA Moreapplication application process market-likeActorsTaxpayer Experience of Level of preference and New methodology of Higher level of knowledge Yesthe taxpayer experience with APA reducing tax risk for and know-how due toprocesses selected transactions ‘experience’ and ‘expertise’Tax Experience Dedicated APA resources Low level of experience The APA Program explicitly Yesadministration of tax such as APA personnel, with advance ruling in the dealing with APAsadministration resources, procedures area of ‘transfer pricing’ The APA unit within theNo specialized APA federal tax administrationProgram and unit with with dedicated tax expertsdedicated tax experts and and economistseconomistsTax consultant Experience of Average number of APA Small number of cases Large number of cases Yestax consultant cases per transfer pricing No specialized APA Specialized APA consultancyconsultant consultancy within the ‘Big Four’ taxconsulting firmsOECD Impact from Acceptance/Incorporation Yes; Partly; Yesinternational of international regime Vice versa, Germany Vice versa, USA significantlyorganization principles by national tax partly has impact on influences OECD positionsadministration OECD on transfer pricingguidelines137a In Germany, the upcoming constitutional reform of the federal system of legislative approval by the second chamber (Bundesrat) may bring in changes inlegislative and executive authority in the field of tax assessment and tax revenue redistribution.