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  • APA and MAP program management unit

    The APA / MAP program management unit (PMU) manages our advance pricing arrangements (APA) and mutual agreement procedure (MAP) programs and oversees the competent authority (CA) network.

    Our functions include:

    • managing the APA workflow and process, including negotiating bilateral advanced pricing arrangements
    • providing assistance under the MAP article contained in Australia’s tax treaties
    • issuing competent authority determinations under the ‘limitation of benefits’ and recognised stock exchange rules where they exist in relevant tax treaties
    • negotiating dual residency mutual agreements for non-individuals under Article 4(1) of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) where that Article applies to a tax treaty.

    Enquiries about an application for an APA, MAP or a CA determination can be directed to the PMU.

    Initial contact with PMU can be made by:

    APA/MAP Program Management Unit

    Public Groups and International

    Australian Taxation Office

    GPO Box 9977

    Brisbane QLD 4001

    When you lodge an APA early engagement form or apply for MAP relief, you will be advised of the team and competent authority who will be working on your case.

    PS LA 2015/4 Advance Pricing Arrangements

    Law Administration Practice Statement PS LA 2015/4 Advance Pricing Arrangements provides detailed guidance on advance pricing arrangements. It also contains a diagrammatic overview of the process for entering into an APA.

    PS LA 2015/4 draws upon lessons from the successful implementation of the early engagement approaches used for the processing of private ruling applications.

    It reflects a:

    • principle-based approach
    • streamlined process and practices to improve timelines
    • reduction in red tape.

    If you are interested in entering into an APA, familiarise yourself with PS LA 2015/4

      Last modified: 09 Aug 2022QC 43088