New Advance pricing arrangement practice statement

Practice Statement Law Administration PS LA 2011/1 (APA LAPS) replaces Taxation Ruling TR 95/23, which provided guidance on the previous Advance pricing arrangement program (APA program).

This practice statement sets out the features of the renewed APA program developed by the members of the APA co-design committee, made up of representatives from the:

• accounting profession
• Corporate Tax Association
• Australian Taxation Office (ATO).

The APA co-design committee considered recommendations from an independent review of our APA program by PwC Legal and suggestions from:

• members of the National Tax Liaison Group Transfer Pricing Sub-Group
• the Large Business Advisory Group
• ATO staff.

To avoid surprises in the analysis phase of the APA, this practice statement outlines processes that ensure issues are identified upfront and the approaches to resolving them are agreed with the taxpayer. The statement of mutual expectations in this practice statement promotes frank and open dialogue between us and the taxpayer and a joint commitment to develop an APA.

For more information, refer to our New guidance on Advance pricing arrangements media release.