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End of attention

APA processing times

Our past practice has been to aim at completing an APA within 12 months after the application is lodged. However, in March 2011, we introduced new APA products with different targeted completion times.

Figure 1: Target cycle time from pre-lodgment to finalisation (months) for new APA products


APA products





Types of APA products






Target cycle time from pre-lodgment to finalisation (months)(a)





(a) It is expected that the pre-lodgment phase would take between one to three months depending on the type of APA product.

We expect the taxpayer to cooperate and provide timely, detailed and accurate information. Completing the APA process within the target timeframe months depends on the:

  • length of time the applicant takes to lodge the application
  • availability of information
  • amount of cooperation between us, the taxpayer and the foreign tax authority.

This time taken can also depend on the resources we have available to undertake the process. All of this year's completed APAs were commenced prior to the release of the new practice statement.

On average, the APAs completed in 2010-11 took 14 months to process (16 months median) from lodgment to finalisation, compared to 12 months in 2009-10. Fifty seven percent of APAs were completed in 12 months or less and 6% took 36 months or more. On average, seven months was spent in pre-lodgment.

The average (median) time for completing:

  • unilateral applications was 9 (six) months, compared to five months in 2009-10
  • bilateral applications was 21 (24) months, compared to 25 months in 2009-10.

This year, on average:

  • a renewal application took 25% less time to process compared to a new application - 14 large business and international (LB&I) APAs were renewals, which took an average of 17 months to process
  • an application involving an SME taxpayer took 70% less time than one involving a large business taxpayer, compared to 68% in 2009-10 - 14 new SME APAs were completed in an average time of eight months.

In nine SME APA applications, we had undertaken compliance activity such as a transfer pricing risk assessment. Our knowledge of the businesses contributed to faster processing times for these applications, which were usually unilateral. SME piloted our simplified processes in a number of applications.

Figure 2 shows our performance over the last nine years.

Figure 2: Average time in process: APAs by type

Shows are performance over the last nine years

    Last modified: 06 Mar 2015QC 25181