Confidentiality is not guaranteed: confidentiality is also a major concern, given that important group directives and trade secrets are communicated by taxable persons to the tax authorities when the APA is concluded. The information that will be shared with tax authorities upon completion of an APA should be treated with great care. The information shared by a taxpayer when negotiating an APA may include group policy, pricing policy, future business projections and revenue model, which are of strategic importance to the multinational group. Sharing them with competitors can have a negative impact on taxpayers` position in the market. The industry is very concerned about the possibility of misuse of data by tax authorities. Tax authorities may use this information as possible comparable information vis-à-vis taxpayers who have not received an APA. . . .