. Prior to the establishment of commercial relations between affiliated companies from different States, the tax agreement establishes a method for determining transfer pricing for certain commercial incidents for a specified period. Search results: 20. Exactly: 20. Processing time: 216 ms. See also Tz on this subject. 4.123 of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration of 22 July 2010[1], as well as the letter of 5 October 2006 from the BMF: Fact Sheet for bilateral or multilateral arbitration proceedings on the basis of double taxation treaties for the issuance of binding advance pricing commitments between internationally related companies (APAs).