APAs in Australia, Canada and the United States: current developments and future directions
(2006) APAs in Australia, Canada and the United States: current developments and future directions. Intertax 34(8-9):pp. 393-404.
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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.
| Item Type: | Journal Article |
|---|---|
| RM Number: | 2007000848 |
| Status: | Published |
| Keywords: | Australia, Canada, United States, APA programs, ATO, CRA, IRS, cross-border transactions |
| Subjects: | 390000 Law, Justice and Law Enforcement > 390100 Law > 390118 Taxation Law 390000 Law, Justice and Law Enforcement > 390100 Law |
| ID Code: | 5037 |
| Deposited By: | Hoshiko, Nami |
| Deposited On: | 18 September 2006 |
| Alternative Locations: | http://www.kluwerlawonline.com/toc.php?pubcode=TAXI |
| Copyright Owner: | Copyright 2006 Kluwer Law International |
| Copyright Statement: | Reproduced in accordance with the copyright policy of the publisher. |
| Additional Information: | m.markham@qut.edu.au |