Does the country have a pre-price program (APA)? If so, is the program widespread? Are there unilateral, bilateral and multilateral APAs? After the APA takes effect (which also requires the agreement of the subject and the waiver of the right of appeal) and at the request of the subject, the local tax authority must make a binding decision reflecting the agreement reached in the APA. Taxpayers work in an increasingly regulated business environment, where transparency is essential. Taxpayers need a certain degree of security in managing their tax and potential exposure to risk. Pre-price agreements (APAs) help provide this security to taxpayers. There are some factors that pose difficulties in reaching an agreement on AAP with the DGT: the provisions of the Pre-Price Agreement (APA) are not new, but so far their practical importance has been rather limited. The APA is an agreement between the subject and TA, which defines in advance the basis of the tax calculation, the methods of determining taxable prices and the length prices of one or more transactions with related persons over a period of time. The main advantages of ASAs are minimizing transfer pricing disputes, ensuring legal certainty and easing the calculation of taxes. AAPAs are handled by specially trained staff from the Federal Office of Taxation (also responsible for mutual agreement procedures) who will coordinate cases with the relevant local tax authorities involved in the APP process and will often prepare the technical analysis. This coordination can simplify future processes and audits and optimally create an open and collaborative relationship between all parties involved.
However, from the point of view of the subject, it should be taken into account that, according to the general rules of procedure, the tax authorities can use all the information obtained in an APA procedure to the detriment of the subject and even if, in the end, no APA is concluded. The German tax authorities regularly conclude bilateral and multilateral APAs (unilateral decisions on transfer pricing with effect in the future are granted only in exceptional circumstances). AAPas are an increasingly widely used tool: 56 APP requests were sent to German tax authorities in 2018 and 43 bilateral and multilateral APAs are in effect according to the EU Joint Forum on Transfer Prices at the end of 2018. Human language is a much more sophisticated tool that allows instructions and requests to be transmitted more effectively in the field. The mechanical load and cognitive load of man is much lower if we can pronounce a sentence like “Alexa, how is my shuttle?” compared to the cognitive and mechanical 30 steps with the best smartphone and the best applications. The alternative to language requires the cognitive load of the brain and the mechanical load to type with the cognitive load of the brain, to interpret what a map can relate. Asking a question is much higher. An APA is a contract, usually several years, between a tax payer and at least one tax authority, which indicates the pricing method that the taxpayer will apply to transactions with related companies. These programs are designed to help policyholders proactively and cooperatively resolve voluntary or potential transfer pricing disputes as an alternative to the traditional verification process. An APA offers other benefits to a company. It provides greater security in the transfer pricing method, reduces the possibility of litigation and facilitates financial reporting on potential tax liabilities. It is important that the APA also reduce the impact of double taxation and the costs of defending reviews and preparing documentation.
Voice computers seem to have limits to what can be achieved. However, if we really analyze the exact results we are looking for, the vast majority of people may simply receive a “yes” or “no” answer.