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  • Early engagement stage

    You can apply for an APA by completing a request for advance pricing arrangement early engagement form. The completed request needs to contain an outline of the APA you propose.

    Information you should provide is set out on the request form and includes:

    • name and tax residence country of the other parties involved in the proposed APA
    • explanation of how the Australian operations fit into the global structure of the group
    • outline of the roles of the Australian entities within the global value chain
    • term of the proposed APA
    • cross-border dealings to be covered by the proposed APA
    • other cross-border dealings not to be covered by the proposed APA
    • proposed transfer pricing methodology
    • collateral issues
    • critical dates.

    You may consider providing additional information with your request which may include:

    • global group structure
    • role of Australian entity in the multinational entity (MNE).

    During the early engagement stage, we will work with you to develop a plan for the early engagement stage and a draft plan for the APA application stage.

    Next step:


    When the Internationals Gatekeeper receives the completed request for early engagement, the APA request will be assigned to an APA team. Where necessary, an officer from the APA team will contact you to confirm our understanding of the APA proposal. The request is reviewed at triage and at the APA request review workshop. At the workshop a decision is made whether to progress the APA request.

    If your APA request is not going to progress, you will be advised in writing of the reasons for that decision. If you are unsatisfied, you can make further submissions to the APA team leader. If the APA request is still not accepted, you may submit a request for an internal review of the decision to the Internationals Gatekeeper. This review is undertaken by the head of the APA/MAP Program Management Unit or another senior officer with no prior involvement in your APA request.

    Preliminary discussions

    Preliminary discussions are held as part of the cooperative relationship that underlies our entering into an APA. The aim of these discussions is to explore avenues for the appropriate treatment of the covered cross-border dealings and any collateral issues.

    Openly discussing your APA request should stimulate a free flow of information between us and lead to a more robust review of the request and any supporting documentation. Further information about preliminary discussions from our perspective is available in PS LA 2015/4 Advance Pricing Arrangements. At the end of these discussions we will know what to expect if and when you lodge a formal APA application.

      Last modified: 23 Mar 2021QC 43088