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  • Mutual expectations

    The APA process is a co-operative one requiring a relationship of mutual trust between the parties to achieve an effective outcome. Expectations we may have of each other include:

    • all parties will co-operate fully with each other, including undertaking open and ongoing dialogue in the development of the APA
    • each APA request will be treated on its merits according to its own facts
    • each party will act transparently, in particular each party will disclose all relevant and material facts
    • each party will provide prompt and complete replies to any reasonable queries.

    Any information you provide in the course of the APA process may be provided to the other tax authority where a bilateral or multilateral APA is being sought. You may withdraw from the APA process at any time.

      Last modified: 15 Dec 2021QC 43088