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.
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.
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|Item Type:||Journal Article|
|Keywords:||Australia, Canada, United States, APA programs, ATO, CRA, IRS, cross, border transactions|
|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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