Advance Pricing Arrangement (APA)


Symbolic picture.

An APA is an agreement with which the methodology, critical assumptions and other appropriate criteria for determining the transfer pricing for these transactions are defined, along with the period for which these criteria apply, before the execution of transactions between related parties. The competent authority for all types of APA agreements is the Financial Administration of the Republic of Slovenia.

The APA agreement is intended for all companies that enter into transactions with related parties and which are persons liable for tax under the act governing corporate income tax. The APA agreement is particularly suitable for multinational companies that consider themselves to be an important part of the society and whose strategies include not only commitments promoting care for the environment, care for employees, customer care and care for turning profits, but also a commitment to compliance with statutory tax liabilities, and are willing to correctly disclose and explain all the facts and circumstances of a related transaction that will comprise the subject of the APA agreement.

National legislation


  • Tax Procedure Act GB


  • Rules on implementation of the Tax Procedure Act SI