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APAs in Australia, Canada and the United States: current developments and future directions

Markham, Michelle A. (2006) APAs in Australia, Canada and the United States: current developments and future directions. Intertax, 34(8-9), pp. 393-404.

Abstract

Australia, Canada and the United States have all in recent years introduced more severe penalties for non-compliance with transfer pricing documentation rules. At the same time, they have taken steps to enhance their APA programs to deal with the ensuing proliferation of transfer pricing controversies. These countries have also adopted the practice of issuing annual reports of their APA programs, documenting such issues as APA processing times, types and methodologies, along with the perceived benefits of entering into an APA from the point of view of the ATO, the CRA and the IRS.

This paper will provide a comparative review of the abovementioned APA programs, looking at recent developments and outlining future directions.

Impact and interest:

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ID Code: 5037
Item Type: Journal Article
Additional Information: m.markham@qut.edu.au
Additional URLs:
Keywords: Australia, Canada, United States, APA programs, ATO, CRA, IRS, cross, border transactions
ISSN: 0165-2826
Subjects: Australian and New Zealand Standard Research Classification > LAW AND LEGAL STUDIES (180000) > LAW (180100) > Taxation Law (180125)
Australian and New Zealand Standard Research Classification > LAW AND LEGAL STUDIES (180000) > LAW (180100)
Divisions: Current > QUT Faculties and Divisions > Faculty of Law
Copyright Owner: Copyright 2006 Kluwer Law International
Copyright Statement: Reproduced in accordance with the copyright policy of the publisher.
Deposited On: 18 Sep 2006
Last Modified: 29 Feb 2012 23:18

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