. See also Tz. 4.123 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration of 22 July 2010 and the BMF letter of 5 October 2006: Fact Sheet bilateral or multilateral pre-agreement procedures on the basis of double taxation agreements for the granting of binding prior commitments on transfer pricing between international companies (“Advance Pricing Agreement” (APAs).  The tax agreement defines, prior to the establishment of business relationships between associated companies in different states, a method for determining transfer prices for certain transactions for a specified period of time. As the leaks from Luxembourg have learned, the number of advance transfer pricing promises has increased from 119 to 519 in Luxembourg in two years since 2013 and from 10 to 411 in Belgium during the same period. Advance Pricing Agreements (AAS) is an agreement reached as part of a pre-agreement procedure in the area of transfer pricing between one or more taxpayers and one or more tax administrations. In Germany, the cost of the application is governed by Article 178a AO. ..