All the taxable person`s documents are returned to the taxable person if the taxable person`s ABS application is not approved or cancelled by the DGT. No documentation during the APA process may be used by DGT for tax audit and investigation purposes. Mutual agreement cases were handled by the Directorate of International Taxation. An Advance Pricing Agreement (APA) is an agreement between tax authorities and taxpayers on the future application of the transfer pricing policy. . . .