The above problems cannot be resolved simply by the appropriate adjustment mechanism under Article 9, paragraph 2, or by the Mutual Agreement Procedure (MAP) under Article 25 of the OECD Model Convention (OECD model). As the name suggests, the agreement, this agreement is made before the fiscal year or transaction comes into force. In order to determine, against existing transactions, the amount of the price to be reported to the tax office. If agreed, the agreement binds the taxman and the taxpayers. The price agreement consists of 2 words, namely price and agreement In addition to the “price agreement”, you can also look for an explanation for the following words: With the ease of resolving transfer pricing conflicts by appropriate adjustment and MAP, then developed another billing system called Advance Pricing Agreement (APA). The contract price consists of 2 words, i.e. the contract and the price The following is a translation of the importance of the price agreement of the English term in Indonesian in the English-Indonesian dictionary The first maintenance request above must be filed no later than 6 (six) months before the start of the fiscal year to be processed in the APA. In principle, bilateral and multilateral APAs, developed from Article 25 of the OECD model. This is due to the sound of Article 25, paragraph 3 of the OECD model, which states that tax authorities can resolve disputes because of differences in OECD interpretation or application through POPs and that one country`s tax authorities can discuss multiple taxation prevention with tax authorities in other countries in cases that are not specifically regulated by the OECD model. . The APA can be unilateral, which is an agreement between the Director General of Taxes and taxpayers. Or bilaterally, i.e. the agreement of the Director General of Taxation with other state tax authorities regarding taxpayers who are in their territory.

3. The submission of the APA in paragraph 1, point b) is made through the tax administration of the partner state or the jurisdiction of the partner. Taxpayers, through the Tax Directorate II, send a written request to the Tax Directorate, with a copy to the head of the Tax Services Office, which is headquartered in the tax administration, to conduct preliminary interviews. (Appendix 1, point 69/PJ./2010) Thus, under international, bilateral and multilateral tax legislation, the APP is included in Article 25 of the OECD model. Parties to apa, i.e. taxpayers and tax authorities, are required to sign the agreed APA so that the content of the agreement is binding in the APP and cannot be changed either by a court decision or by judicial review of the country participating in the APP.