On 12 January 2022, the Australian Taxation Office (ATO) has announced that it is undertaking a review of its advance pricing arrangement (APA) program.
The APA program provides a valuable service delivering certainty on dealings with international related parties. ATO 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; and
- assuring transfer pricing risk in the most efficient manner possible.
The review will commence in early 2022. ATO plans 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; and
- what arrangements / transactions are viewed as most desirable for an APA.
