Australia: Initial steps for APA process

Australia: Initial steps for APA process

The Australian Taxation Office (ATO), as part of a comprehensive approach, introduced a new initial step for the advance pricing arrangement (APA) process—currently known as the “Triage Review Panel.”

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The purpose of the Triage Review Panel is to:

  • Allow the ATO to identify any significant risks upfront
  • Decide whether the APA progresses to an APA pre-lodgement meeting
  • Provide initial recommendations and specify key information that will be required

What is the effect for taxpayers? This means that a lot of the technical work that needs to be undertaken for an APA submission must, to some extent, be done upfront (e.g., functional analysis, financial forecasting, proposed transfer pricing methodology, and collateral issues considered).

Once the Triage Review Panel step has been completed, the remaining steps for the APA renewal remain unchanged. The remaining five steps are a pre-lodgement presentation and meeting; lodgement of formal APA submission; analysis/evaluation; negotiation and agreement; and finalisation.

 

Read a February 2015 report prepared by the KPMG member firm in Australia: New and renewed APAs – the keys to success

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