and the terms of the
agreement. A taxpayer wishing to apply for an APA must first submit
a written document of intent for a pre-filing meeting at least six
months prior to the last day of the first accounting period in which
the APA aims to become effective. Certain documents relating to the
covered transactions and the functional profiles are required to be
submitted at least 15 days prior to the first pre-filing meeting. Once
the pre-filing meetings process has been successfully accomplished
and the Revenue officers have agreed that the application may be
submitted, the applicant may officially apply for the APA.