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End of attention
We encourage potential APA participants to take full advantage of discussions with us before lodging a formal APA application. They can use the pre-lodgment meetings with us to discuss:
- whether their case is suitable for an APA
- the scope of the transactions that are to be covered
- their preliminary views on the transfer pricing method
- the information they will need to give us so we can properly look at their request before lodging a formal application.
Many proposals are complex or unique. Applicants must provide background material and an outline of their proposal well before the meeting, so:
- we can use the meeting time well
- we can offer considered views
- the most appropriate staff can attend.
It is important to agree on the scope of the APA at an early stage. This can affect the level of our analysis of the application. The application should reflect the outcome of the pre-lodgment discussions and should contain no surprises. Sometimes other issues (for example, capital gains or income and expense recognition) may need to be considered either separately or in conjunction with the APA. How and when these matters are addressed is best agreed at the start of the process. Depending upon the nature of issues we may deal with them before, concurrently or after considering the APA.
The length and nature of the APA pre-lodgment process is largely responsive to the needs of the potential applicant and the nature of their proposal. Applicants enter pre-lodgment discussions at different stages of preparedness in making their APA proposals. As a result, it can take applicants significantly different lengths of time to progress to lodgment.