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Mutual expectations

Last updated 26 July 2023

The APA process is a co-operative one requiring a relationship of mutual trust between the parties to achieve an effective outcome.

Expectations we may have of each other include:

  • all parties will co-operate fully with each other, including undertaking open and ongoing dialogue in the development of the APA
  • each APA request will be treated on its merits according to its own facts
  • each party will act transparently by disclosing all relevant and material facts
  • each party will provide prompt and complete replies to any reasonable queries.

Any information you provide during the APA process may be provided to the other tax authority where a bilateral or multilateral APA is being sought. You may withdraw from the APA process at any time.

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