ATO releases newguidance regarding the Advance pricing arrangement (APA) program .
The ATO today released new guidance regarding the Advance pricing arrangement (APA) program. Increased demand combined with more complex business arrangements have required the ATO address the way the APA system is handled.
For more comprehensive references please see: Practice Statement Law Administration PS LA 2011/1 which replaces the ATO’s previous guidance, Taxation Ruling TR 95/23.
The APA can be:
- unilateral : between us and the taxpayer
- bilateral :
between us, the taxpayer and one tax treaty partner
- multilateral :
between us, the taxpayer and more than one tax treaty partner
Currently there are 109 APA's in place: 58 APAs with large business and 51 with small to medium enterprises.
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