The Australian Taxation Office in 2022 is conducting a review of its advance pricing arrangement (APA) program, according to a January 12 announcement. The review will focus on whether the program is assuring transfer pricing risk in the most efficient manner, as well as whether the APA program is providing the right service for all taxpayers.
The review will also evaluate how to modify the APA process to better align with risk and taxpayer behavioral indicators. The ATO is interested in how it can better tailor the program for “the full spectrum of potential risks” that may come up under an APA.
ATO plans subsequently to announce consultations in connection with the review. The agency notes that it will be particularly interested in hearing from stakeholders regarding market perspectives of the APA program, what about the program is appealing, and the types of arrangements and transactions for which taxpayers are most interested in APAs.
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