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13.4.4. APAs and Dispute Resolution Mechanisms


Advanced pricing agreements (APA) are technically available under law, and can be requested for up to 4 years. However, the procedures to apply for an APA have not been developed.


If an adjustment is proposed by the tax authority, the taxpayer has the right to appeal through the same appeals process for other tax adjustments/assessments (Covered Sec. 14.7.).