KPMG International’s survey found that once a company has decided to enter an APA, the process for completing it is fairly consistent among the countries that offer them. In some countries, the issuance of queries and submission of documentation during the fact-finding phase can be reiterated many times over, requiring almost as much documentation as that required on an audit. In other countries, more time is spent negotiating and confirming details during the pre-filing stage.
While the process itself is similar, respondents reported wide variations in the ease of navigating the process. The formality of the process and the , level of responsiveness vary by country. Some of this depends on the demand for APAs and the tax authorities’ experience with these agreements.