Advance pricing arrangements: Are Australia's recent reforms relevant to Canada?
Date of this Version
In Canada, the Canada Revenue Agency (CRA) has implemented a number of procedural changes to its apa program over the past year, including the introduction of certain restrictions on entry into the program. Canadian tax advisers have expressed concern that the cra’s rejection of some apa applications, driven largely by resource constraints, may be detrimental to the program. This article examines the “best practice” changes that have recently been introduced in relation to apas in Australia, and considers whether any of these changes might be able to inform and assist tax reform in this area in Canada.
This document has been peer reviewed.