The APA may be reviewed, terminated, revoked or renewed depending on the circumstances. The revision of the APA occurs when a violation of critical assumptions about factors and assumptions that are so critical and significant that no partisan conclusion of an agreement is always bound by the agreement if any of the factors or assumptions are changed. An APA is an administrative approach that aims to avoid transfer pricing disputes by establishing criteria for applying the arm length principle to transactions prior to such transactions. This contrasts with traditional audit techniques that verify whether transactions that have already taken place reflect the application of the arm length principle. Such approaches were relatively new at the time the 1995 OECD Council adopted the guidelines, and the tax committee therefore indicated, in point 4.161 of the transfer pricing guidelines, that it intended to «carefully monitor any extensive use of the APA and promote greater consistency in practice among countries that choose to use them.» In addition, point 4.163 of the guidelines states that «if possible, an APA must be concluded on a bilateral or multilateral basis between the relevant authorities as part of the treaty`s mutual agreement procedure.» A Pre-Pricing Agreement (APA) is a procedural agreement between one or more tax payers and one or more tax authorities, which aims to avoid transfer pricing disputes by pre-defining a set of criteria for certain cross-border controlled transactions within a specified time frame, to ensure that they respect the length-of-arm principle. We help you defend the transfer pricing policy on your behalf. We can negotiate preferential price agreements (APAs) with the tax authorities and represent you in reciprocal agreements and arbitration procedures. The Office of Internal Revenues («BIR») in the Philippines is about to publish its first APA guidelines. It goes without saying that a multinational company has indicated to BIR its intention to include an APA and that, as a result, the BIR has accelerated the development and future publication date of the APA guidelines as a result of such a measure. The IRB has so far had no experience with the AAAs conclusion, but has suggested that it sees AAAs as an attractive option to secure the tax base and reduce uncertainty surrounding tax collections. In order to achieve ambitious tax collection targets, bir is devoting considerable resources to the development of its transfer pricing and enforcement compliance regime. The publication of the APA guidelines in the near future will be followed by the publication of formal transfer pricing documentation guidelines and transfer pricing control and review guidelines, both of which are under development.