Skip to main content
Reform Support
Europe is connected through communication technology to the global internet network. European connection lines for data transfer and communication. IoT, business, money, and security

Supporting reforms to ensure efficient and effective revenue administration and public financial management

Funding Programme
  • 2021

Streamlining the processes of conducting Advance Pricing Agreements

The Commission provided technical support to the revenue authorities of Poland and Slovakia with the aim of streamlining their Advance Pricing Agreement (“APA”) procedures and establishing a more digitalized APA process (Poland). The technical support would facilitate the authorities to effectively deal with the increasing numbers of APAs.


Both beneficiary authorities’ existing APA practices are growing and expected to require substantial capacity in order to properly process all requests. It is anticipated that the increasing level of resources required to manage their APA practice might adversely impact their regular tax practices. A good functioning and efficient APA practice will limit the drain on resources while maintaining the positive impact on the investment climate and the opportunity for compliant taxpayers to obtain advance certainty.

Support delivered

  • At the end of the 20-month project, the beneficiaries have at their disposal:
  • A comparability analysis regarding the APA procedures of selected best practice countries; 
  • Attained knowledge from an interactive 3-day workshop;
  • 22 recommendations for adoption of best practices of APA processes in Poland and Slovakia categorized based on level (high, medium, low) of impact on the APA practice;
  • Baseline for guidelines for taxpayers and tax officials; and
  • Recommendations on the optimization of a more digitalized APA process (Poland)

Results achieved

The technical support aided the national authorities of Poland and Slovakia in setting out a path for further improving and optimizing their internal procedures in respect of APA proceedings. The Polish authority also obtained a detailed process flow analysis to facilitate the further digitalization of its APA processes. Having effective APA procedures in place will stimulate transparent discussions with taxpayers in advance and contribute to a more compliant and transparent tax practice that is aligned with EU standards. It will also improve the business environment by increasing tax certainty. An efficient APA process will also enable the beneficiary countries to effectively tackle the international problem of tax evasion and tax abuse and increase their national tax revenues.

More about the project

You can read the final report: