How do Unilateral APAs overcome the issues of legitimate expectations, tax transparency and state aid in the European Union?
Advance pricing arrangement (“APA”) becomes a common tool to attract foreign investors to carry out their business in the Member States’ territory. The advantage of APA which providing legitimate expectations to the taxpayers is one of the reasons of why the companies file an APA request to the tax authorities. However, APAs are not free from issues or problems arose, especially in relation to t