APAs and POPs are managed under the same sub-directorate. In accordance with the OECD Guidelines, the US Tax Administration (IRS) also advises the creation of abs in a bilateral or multilateral form. However, to make bilateral or multilateral ABS, it requires a lot of time and costs that are not negligible, which must be borne by the taxpayer. As a result, taxpayers tend to choose unilateral APAs over bilateral or multilateral APAs. Taxpayers request in writing from the Directorate-General for Taxation, through the Director of International Taxes, a wave from the Head of the Service Office of the Domicile Tax, in order to conduct the first interviews (prelodgement) using the APA 1 form by attaching the conditions in accordance with the applicable provisions. It is not easy to resolve the above problems by the appropriate adjustment mechanism referred to in Article 9(2) or by the mutual agreement procedure (MAGP) provided for in Article 25 of the OECD Model Agreement (OECD Model). . . .