According to recent reports, the Panama tax authority (DGI) has prepared draft legislation to introduce amendments to the Tax Code that would provide for advance pricing agreements (APA). The draft sets out the general requirements for an APA application, which are fairly standard, including identification of the taxpayer, the related party, details of the covered transactions, the period covered, proposed transfer pricing methodology, assumptions made, etc. The draft also provides that the DGI would have 12 months from the application date to review an application and issue a decision. If an application is rejected, the DGI is to provide details...