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:

  • exchanging information
  • negotiating bilateral advanced pricing arrangements
  • issuing our determinations under the 'limitation of benefits' and recognised stock exchange rules where they exist in relevant tax treaties
  • assistance in collection.

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.

End of attention

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: 03 Jul 2014QC 18377