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APAs – Australia’s 3-tiered approach 

In 2011, the Australia Taxation Office (ATO) introduced two new pathways – one simplified and one complex – to complement its standard APA process. With separate processes based on levels of complexity, this approach eases and expedites the process for simpler cases and allows more complex cases to receive the level of attention necessary to achieve an appropriate outcome.
  • Simplified APA. Designed for companies with low-value or low-risk cross-border intercompany dealings, this process is available for unilateral APAs only. Companies must meet specified low thresholds based on revenue or transaction values to qualify.
  • Standard APA. Intended for less complex intercompany dealings that do not qualify for the simplified APA or complex APA products, the standard APA process may include collateral issues and is available for both unilateral and bilateral APAs.
  • Complex APA. Designed for companies with complex and/or high-risk cross-border intercompany dealings, the complex APA process may include collateral issues (including where no ATO position exists for their resolution) and is available for both unilateral and bilateral APAs.

The ATO has also set target times to finalize a typical APA of each type to hold the ATO accountable for moving through the process efficiently.

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