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14 January 2022

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ATO Reviewing Advance Pricing Arrangement Program

The Australian Taxation Office (ATO) has announced that it is undertaking a review of the advance pricing arrangement program in 2022, which will include an extensive consultation with taxpayers and advisors.


We are reviewing the advance pricing arrangement program

The advance pricing arrangement (APA) program provides a valuable service delivering certainty on your dealings with international related parties.

We remain committed to the APA service and always look for opportunities to improve, ensuring it aligns with our broader objectives and market guidance. As such, we will be undertaking a review of the program in 2022, primarily to focus on:

  • whether the APA product continues to be providing the right service for all taxpayers
  • assuring transfer pricing risk in the most efficient manner possible.

As part of the review, we will consider how to tailor the APA process to better align to risk and taxpayer behavioural indicators.

We already have a streamlined APA product for early engagement requests from the medium and emerging market, where a combined triage and APA review workshop is used with less intense work during the APA Application stage.

We are now exploring how to similarly tailor the APA experience across the full spectrum of potential risks encountered during an APA engagement.

The review will commence in early 2022. We expect to consult extensively with taxpayers and advisors as part of the process to understand:

  • the market perspectives of the APA product
  • why it is appealing
  • what arrangements / transactions are viewed as most desirable for an APA.

We will notify you when consultation opens.

More information:

Advance pricing arrangements

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