Number of APAs drops in Australia
October 21, 2009
The number of advance pricing arrangements (APAs) has dropped in Australia, figures from the country’s tax authorities have revealed
Figures from the Australian Tax Office showed that 29 APAs were completed during 2008-2009, compared to 48 in 2007-2008.
Of those 29, 13 were renewals, nine were new APAs encouraged by compliance activity, while seven were unprompted.
Of the 29 completed APAs, about half were with taxpayers whose revenue was more than A$250 million ($231 million). The rest were with taxpayers with turnover between A$2 million and A$250 million.
As in previous years, the transactional net margin method was most commonly used in the agreements. This is because many businesses had access to independent comparable data. The comparable uncontrolled price method was the second most popular method.
The time to process an APA from lodging the application to finalisation stayed the same at 11 months. The average time for completing unilateral APAs was 10 months. For bilateral arrangements it was 12 months .
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