Overhauling the Advance Pricing Arrangement framework, the ATO completes significant update

The revised framework is a move in the right direction, with additional guidance and commentary addressing mutual expectations, collateral issues, and streamlining the early engagement stage of an APA, as outlined by Sean Madden and Akash Mundhra.

The Australian Taxation Office (ATO) has completed a significant update to its Advance Pricing Arrangement (APA) framework in PS LA 2015/4, more than two years after publishing findings from a review into the APA program. A framework due for modernisation The APA program has long been a foundation of the ATO's cooperative compliance approach, allowing Multinational Enterprises (MNEs) to agree in advance on transfer pricing outcomes for cross-border dealings. By doing so, both taxpayers and...

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Authors: Sean Madden, Akash Mundhra

Published Date: 31 October 2025