TRANSFERNE CIJENE I INSTITUCIONALNA HARMONIZACIJA: ANALIZA PROVEDBE APA SPORAZUMA U EUROPSKOJ UNIJI
TRANSFER PRICING AND INSTITUTIONAL HARMONISATION: AN ANALYSIS OF APA IMPLEMENTATION IN THE EUROPEAN UNION

Summary/Abstract: This paper analyses the status and harmonisation of Advance Pricing Agreements(APAs) within the European Union for the years 2017 and 2023, using data from the EU Joint Transfer Pricing Forum. The research focuses on four key dimensions: the types of APA agreements, the total number of agreements concluded in EU and non-EU countries, the existence and level of fees for their conclusion, and the average duration of the negotiation process. The aim of the analysis is to identify national progress and regional differences in the implementation of APAs, as well as to assess the administrative efficiency of tax authorities across member states. Special attention is given to a comparison with the findings of Perčević (2019) and to evaluating the effects of the BEPS initiative on the EU’s regulatory framework. The results indicate a gradual harmonisation of practices and a growing interest in APA agreements, but also reveal significant cross-country differences in fees and processing times. Regarding the number of concluded APA agreements, the findings confirm that the European Union follows a more dynamic transfer pricing policy, characterised by heterogeneous patterns among member states, while relationships with non-EU partners remain more stable and predictable, with lower variability. Differences in fee structures and the average duration of negotiations further highlight the inconsistency of administrative and legal practices, emphasising the need for ongoing harmonisation and optimisation of APA procedures in the international context

• Details
• Contents