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  • Who we are

    We are an authority that provides assistance to people who believe the actions of Australia or a treaty partner either result, or may result, in taxation that is not in accordance with a particular tax treaty. We generally provide assistance under the Mutual agreement procedures (MAP) article contained in the Australian tax treatiesExternal Link provided by Treasury.

    What we do

    We resolve cases where there is a conflict with the provisions of a tax treaty, such as:

    • juridical and economic double taxation
    • where taxing a particular class of income breaches a rule in the tax treaty.

    Our other functions include:

    See also:

    • Supporting information for Competent Authority determinations under Article 10(3)(c) of the United Kingdom Convention, Article 16(5) of the United States Convention (and similar determination provisions in other tax treaties), and Article 4(1) of the MLI (where the MLI and that Article apply to a tax treaty).

    For general enquiries – such as seeking clarification and confirmation of your tax position in respect of a treaty – we can provide a more timely response if you ask us for assistance and guidance.

    We provide guidance to help taxpayers understand their obligations and entitlements under the laws we administer. However, this guidance is not binding on us.

    A taxpayer who relies on guidance that is found to be incorrect, or misleading, and makes a mistake as a result, will have to pay the tax that would otherwise be payable under the law. However, the taxpayer will be protected against penalties for false or misleading statements, and, if they have relied reasonably and in good faith on the guidance, against interest charges.

    Contact us

    For all transfer-pricing, mutual-agreement procedure cases. Write to us at:

    APA/MAP Program Management Unit

    Public Groups and International

    Australian Taxation Office
    GPO Box 9977

      Last modified: 18 Dec 2018QC 18377