Published Date: 20 Jun 2024
The ATO has revamped its APA program, bringing collateral issues to the fore of the ATO’s consideration of tax risk. While APAs are ostensibly used to obtain certainty for related party transactions, the focus on non-transfer pricing issues and tax risks, particularly international tax risks, has impacted on the progression of many APAs.
This session covers perspectives from the ATO, transfer pricing experts and controversy experts as to how to navigate collateral issues and the APA program.
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