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- BAPA Operational Guidance for Member Countries of the Pacific Association of Tax Administrators (PATA)
Section 1 PURPOSE OF GUIDANCE
The purpose of this guidance is:
- to establish a common approach for treating taxpayers
in a fair and consistent manner when seeking a Bilateral Advance Pricing Arrangement
(BAPA);
- to provide a working framework that enables the smooth and timely
completion of BAPAs; and
- to encourage and facilitate the use of BAPAs among Pacific Association
of Tax Administrators (PATA) members.
Section 2 BACKGROUND AND SCOPE
- This guidance pertains to the manner in which the Competent
Authorities of the PATA members conduct the BAPA process. The PATA members are
committed to the promotion of programs, such as BAPAs, that are designed to increase
certainty for taxpayers that have cross-border transactions between Associated
Enterprises. PATA members also endeavor to make BAPAs and the underlying Domestic
APAs available to taxpayers in an efficient and cost-effective manner.
- The acceptance and evaluation of a taxpayer’s BAPA
request and the negotiation and coming-into-force of its resolution are done
by the Competent Authorities pursuant to the pertinent provisions of the relevant
bilateral Income Tax Convention (“Convention”) to ensure mutual acceptability
and consistency. See Appendix A for a list of the relevant Conventions. Competent
Authorities endeavor to conclude BAPAs in a timely manner after accepting the
BAPA request and upon receipt of the taxpayer's documentary material giving due
regard to the facts, circumstances and complexity of each case. However, PATA
members may decline BAPA requests that propose to cover certain types of transactions
or organizational structures.
- It is understood that the Mutual Agreement Procedure (MAP)
Article contained in the applicable Convention, together with the administrative
powers granted to the Competent Authorities by their respective governments,
empower the Competent Authorities to reach a resolution on BAPAs. The Competent
Authorities may enter into BAPAs and exchange taxpayer and other information
under the authority of the provisions of the applicable Convention and their
respective domestic law, regulations, and procedures. BAPAs will be resolved
in accordance with the Related Persons/Associated Enterprises, MAP, and Exchange
of Information Articles of the applicable Convention. Multilateral Advance Pricing
Arrangements (MAPAs) are also available to taxpayers. However, a MAPA is still
resolved and implemented through the relevant bilateral Conventions.
- This guidance does not modify any of the rules and procedures
under the domestic law, policies, or procedures of the PATA members dealing with
Advance Pricing Arrangements, or similar such pricing understandings or undertakings
(APAs). If there is any inconsistency between this guidance and the domestic
law, policies, or procedures of PATA members dealing with APAs, the Competent
Authorities shall endeavour to resolve this conflict.
- No term, procedure, or understanding contained in this guidance
shall be construed as superceding the provisions of the relevant Convention between
PATA members, as listed in Appendix A. If there is any inconsistency between
this guidance and a Convention, the provisions of the applicable Convention or
any other bilateral understanding of agreement concerning BAPAs, either in existence
or subsequently concluded, shall prevail.
- The principles of the 1995 Transfer Pricing Guidelines for
Multinational Enterprises and Tax Administrations and its 1999 Annex Guidelines
for Conducting Advance Pricing Arrangements under the Mutual Agreement Procedure
issued by the Organization for Economic Co-operation and Development (OECD),
as amended from time to time, will be used as a guide in resolving BAPA cases.
See Appendix B for the Glossary of Terms used in this guidance.
- The PATA members acknowledge that it is frequently not possible
for the persons delegated as Competent Authority to deal directly with BAPA cases.
Therefore, it may be necessary to have other persons within the office of the
Competent Authority (“analysts”) perform certain functions on behalf
of the Competent Authority.
- Competent Authorities must assure taxpayers that all information
submitted under the BAPA process will be subject to strict non-disclosure standards,
in accordance with Section 7 of this guidance.
Section 3 PRE-FILING / PRELODGEMENT PROCEDURES
- The Competent Authorities encourage the use of pre-filing/prelodgement
procedures that permit taxpayers to explore the requirements, benefits and costs
of pursuing a BAPA. These pre-filing/prelodgement procedures may include:
- an informal meeting between the taxpayer and its Competent
Authority;
- a meeting, if necessary and appropriate, between the relevant Competent
Authorities to discuss the proposed covered transaction(s);
- a meeting, if both Competent Authorities deem it necessary and appropriate,
involving all stakeholders (Competent Authorities and the taxpayer); and
- an evaluation by the Competent Authorities of preliminary information
or analysis provided by the taxpayer for purposes of exploring the appropriateness
of pursuing a BAPA.
- Pre-filing/prelodgement meetings may be held on an anonymous
basis to protect the taxpayer’s identity.
Section 4 MAKING AND ACCEPTING A BAPA REQUEST
- A taxpayer requesting a BAPA between two PATA members is
required to formally request assistance from the Competent Authority of its country
of residence.
- PATA members may have administrative or legislative due dates
after which a BAPA request may be precluded from being accepted for a particular
year. Accordingly, a taxpayer is encouraged to submit a BAPA request as early
as possible in relation to the years intended to be covered by the BAPA. Appendix
C to this guidance sets out the type of information that should accompany a taxpayer’s
BAPA request. To facilitate the expeditious resolution of a BAPA, the Competent
Authorities encourage the taxpayer to submit a BAPA request, and all supporting
material, promptly and simultaneously, to both Competent Authorities.
- If a taxpayer misses an administrative or legislative due
date, it may still be possible to have the year covered through a “roll-back”.
A roll-back is the application of a BAPA to a prior year when there has been
no significant change in facts that would affect the ability of the transfer
pricing methodology (TPM) to produce an arm’s length result for that year.
If a taxpayer is seeking a roll-back it must state this desire, and indicate
the roll-back years to be considered, at the same time as it makes the BAPA request.
PATA members are under no obligation to accept a roll-back of a BAPA.
- When a BAPA request is received from a taxpayer, the PATA
member should acknowledge the BAPA request within thirty (30) days from the date
of receipt. In addition, the Competent Authority of that PATA member should inform
the other Competent Authority of the request within thirty (30) days from the
date of receipt of the BAPA request. Communication between Competent Authorities
and with the taxpayer should be in writing and identify the Associated Enterprise
involved in each country, the transfer pricing issue, and the contact persons
for the Competent Authority and for the taxpayer responsible for the BAPA request.
- In accordance with, and as provided for under, the relevant
Convention, the Competent Authority will inform the taxpayer that all information
and analysis that may be submitted by the taxpayer at any time up to the resolution
of the BAPA are to be simultaneously provided to both Competent Authorities in
a timely manner. Any information received, prepared or generated by a PATA member
in respect of the taxpayer's BAPA request may be exchanged with the other Competent
Authority.
- A taxpayer’s BAPA request will be accepted by a PATA
member when all of the following actions have been completed:
- a) exploratory discussions or meetings in accordance with domestic
pre-filing/prelodgement procedures have occurred, if necessary;
- b) the taxpayer has satisfied all requirements for preliminary information
and explanations established by the Competent Authority;
- c) both Competent Authorities have determined that a BAPA is appropriate;
and
- d) the taxpayer has paid, or agrees to pay in accordance with domestic procedures,
any fees or charges required by the PATA member.
- A Competent Authority should communicate, in writing, with
the taxpayer and the other Competent Authority its decision to accept or decline
a BAPA request. Generally, this communication should occur within ninety (90)
days from the date of receipt of the BAPA request. A Competent Authority may
decline a BAPA request on reasonable grounds, including where a BAPA request
presents facts or circumstances that would preclude the consideration of a BAPA
under its domestic law, policies, or procedures dealing with BAPAs.
- If this time limit cannot be achieved, the Competent Authority
should so advise the taxpayer and indicate the likely timeframe. Where additional
information or clarification from the taxpayer may be required by the Competent
Authority in order to reach a decision to accept the BAPA request, the ninety
(90) day time limit should commence when the additional information is received
by the Competent Authority.
- Before declining a BAPA request the Competent Authorities
should consult. If a Competent Authority concludes that the BAPA request will
not be accepted, it should advise the taxpayer, giving the reasons for such decision.
- In the interest of efficient tax administration and the avoidance
of double taxation, the Competent Authority will generally encourage the taxpayer
to pursue a BAPA should a taxpayer initially seek a Unilateral APA. However,
a taxpayer may choose to conclude a Unilateral APA with a PATA member when the
other Competent Authority has declined a BAPA request, when the Competent Authorities
fail to resolve a BAPA, or when a BAPA is not otherwise possible or practical.
- In the event that a taxpayer concludes a Unilateral APA with
a PATA member, the MAP process will be available to the taxpayer and its Associated
Enterprise if double taxation subsequently occurs. A Competent Authority may
deviate from the terms and conditions of the Unilateral APA, if necessary, to
resolve double taxation.
Section 5 EVALUATION AND NEGOTIATION OF A BAPA
- After the Competent Authorities have agreed to accept a BAPA
request, they will independently and simultaneously evaluate the taxpayer’s
request based upon their respective domestic procedures.
- At the beginning of the evaluation phase, the Competent Authorities
may develop, in consultation with each other and the taxpayer, an action plan
for the timely completion of the BAPA. The discussions may include such matters
as:
- a) the planned scope of analysis and due diligence to be undertaken
by each Competent Authority;
- b) any need for independent experts;
- c) the key issues to be resolved;
- d) the nature and extent of additional information and analysis which the
taxpayer will be required to submit; and
- e) the target dates for the simultaneous exchange of position papers and
for meetings to negotiate the terms and conditions of the BAPA.
- One of the primary responsibilities of the Competent Authorities
is to promote regular communication and coordination between PATA members. The
Competent Authorities are committed to an informal process to expedite the evaluation
and negotiation of the BAPA. To enhance communication, analysts are encouraged
to liaise with their Competent Authority counterparts to discuss or clarify specific
issues throughout the BAPA process. All such discussions between analysts should
be properly documented.
- The documentation required for a BAPA should not be more onerous
than that required for an examination. To enhance coordination, the Competent
Authorities should ensure that taxpayers provide all relevant information and
analysis to both tax administrations at the same time. Where an exchange of information
is necessary, the Competent Authorities will facilitate the prompt exchange of
that information. The Competent Authorities do not need to exchange copies of
all documents provided by the taxpayer but should arrange, amongst themselves,
for an appropriate mechanism to corroborate the completeness and details of documents
and information supplied by the taxpayer.
- During the evaluation stage, the Competent Authorities should
advise each other on their progress at least once every ninety (90) days. Regular
reports may be provided by way of telephone, briefing notes, correspondence,
teleconferencing, face-to-face meetings or any other form of communication acceptable
to the Competent Authorities. The objective of these communications is to ensure
that both Competent Authorities are kept informed of a case’s progress
to facilitate timely resolution.
- The Competent Authorities may facilitate meetings, as necessary,
among the stakeholders in the BAPA process. For example, a joint fact-finding
discussion of the taxpayer’s BAPA request may be worthwhile. Such joint
meetings may include personnel from local examination offices and, at the discretion
of the relevant Competent Authorities, taxpayers and their representatives to
expedite the evaluation of the BAPA request.
- The evaluation of a taxpayer’s BAPA request and preparation
of a position paper by a Competent Authority should be undertaken as a matter
of priority. The PATA members shall endeavor to exchange position papers within
twelve (12) months from the date of the receipt of a complete BAPA request Appendix
D to this guidance sets out the type of information that should be contained
in the Competent Authority position paper. The position papers should be exchanged
simultaneously wherever possible. Position papers and correspondence exchanged
between the Competent Authorities shall not be provided to a taxpayer.
- The Competent Authorities acknowledge that negotiations in
respect of a BAPA may be conducted via means such as letters, facsimiles, e-mail,
telephone, and face-to-face conferences. The Competent Authorities shall determine
which means of communication may be taken on a case-by-case basis. Nevertheless,
the Competent Authorities recognize that face-to-face conferences are often the
most useful means by which to resolve a BAPA case, and should conduct face-to-face
conferences involving their analysts whenever possible and practical.
- It is expected that where a face-to-face meeting is required,
all relevant information will be exchanged at least four (4) weeks prior to the
meeting. This will lead to more efficient and productive meetings, as the Competent
Authorities will have had sufficient time prior to the meeting to give due consideration
to this information.
- In order to achieve a timely resolution of a BAPA case,
the Competent Authority staff with the authority to resolve the case should be
present at the negotiations.
- The Competent Authorities recognise that in some cases interpreters
may be required to help facilitate face-to-face meetings.
- It is understood that the Competent Authorities shall endeavour
to resolve and complete each BAPA case within two (2) years from the date of
the receipt of the taxpayer’s BAPA request. However, in some instances
a Competent Authority may not be able to meet the above timeframe. For example,
this can occur when a taxpayer does not provide supplementary information in
a timely manner or the particular case is unusually complicated. In such situations,
the Competent Authorities may agree to a reasonable extension of the timeframe.
For cases that have exceeded, or are likely to exceed, the two-year timeframe,
senior officials of the two Competent Authorities should undertake a review of
the case to determine the reasons for the delay and then agree on approaches
to ensure the efficient completion of the case.
- The Competent Authorities acknowledge that the negotiation
of a BAPA case is a government-to-government process. While a taxpayer does not
have a legal or other right to attend negotiations between the Competent Authorities
or to observe the negotiations, the Competent Authorities recognize that the
taxpayer is a stakeholder in the BAPA process. Therefore, in exceptional cases,
a presentation by the taxpayer may be helpful in the resolution of the case.
Any such presentation would occur pursuant to a mutual agreement of the Competent
Authorities and would be limited to providing factual information.
- When the relevant Competent Authorities reach a resolution
on the TPM, Critical Assumptions, and any other term or condition, this resolution
shall form the basis of the BAPA.
- Competent Authorities will confirm the BAPA by way of an
exchange of letters that should include the following items:
- a) the names and addresses of the Associated Enterprises that
are covered by the BAPA;
- b) a description of the covered transaction;
- c) a description of the TPM and the agreed tax treatment for other items
such as secondary or compensating adjustments (if applicable);
- d) the term (duration) of the BAPA;
- e) a statement of the Critical Assumptions upon which the BAPA is based;
- f) an agreement to consult before an underlying Domestic APA is revised,
cancelled or revoked;
- g) any agreed procedures to deal with changes in the factual circumstances
that, in and of themselves, would not necessitate the need to renegotiate the
BAPA; and
- h) the terms and conditions that must be fulfilled by the Associated Enterprises
in order for the BAPA and the underlying Domestic APAs to remain valid together
with procedures to ensure that the Associated Enterprises are fulfilling those
terms and conditions (e.g., annual or periodic reports, record keeping, notification
of a breach of a Critical Assumption, etc.).
- 16. The Competent Authorities will communicate the terms of the
resolution to the taxpayer as soon as possible. This communication may take place
prior to the exchange of BAPA letters if mutually agreed to by the Competent
Authorities.
- 17. If the terms and conditions of the resolution are not satisfactory
to the taxpayer, the taxpayer may withdraw from the BAPA process.
- 18. A PATA member should not execute a Domestic APA with a taxpayer
until the exchange of BAPA letters between Competent Authorities has occurred.
- 19. Once BAPA letters have been exchanged, a PATA member should
give it effect in its jurisdiction by providing confirmation to, or entering
into an agreement with, its taxpayer. This confirmation or agreement is referred
to as a Domestic APA. Although the form of the Domestic APA executed by each
PATA member may be different, it is critical that the TPM and Critical Assumptions
be the same as specified in the BAPA to ensure consistency of application by
the Associated Enterprises. A copy of the Domestic APA shall be provided, upon
request, to the Competent Authority of the other PATA member.
Section 6 APPLICATION OF A BAPA
- The term of a BAPA is usually three (3) to five (5) years
and is determined on a case-by-case basis. Should the BAPA take longer than two
(2) years to resolve, the Competent Authorities and the Associated Enterprises
may mutually agree to extend the term.
- To ensure compliance with the terms of a Domestic APA, a PATA
member may require an annual or periodic report from its taxpayer. The taxpayers
should follow domestic procedures and requirements when preparing and filing
this report.
- Each Competent Authority will ensure that all such reports
received from a taxpayer are furnished, upon request, to the other Competent
Authority.
- A PATA member may also have the right to cancel or revoke
a Domestic APA in accordance with its domestic procedures. Cancellation or revocation
may occur if the taxpayer fails to comply with the terms and conditions of the
Domestic APA, including complying with reporting requirements, or if there is
fraud, wilful default or neglect, or gross negligence in relation to the Domestic
APA. The Competent Authority must notify the other Competent Authority, as soon
as possible, of the intention to cancel or revoke a Domestic APA giving reasons
for such action.
- If a Domestic APA is cancelled or revoked, the PATA member
shall retain all rights for those years for which the cancellation or revocation
is effective as though the Domestic APA had not been undertaken.
- If a PATA member challenges a taxpayer’s compliance
in respect of a Domestic APA, the Competent Authority will promptly notify the
other Competent Authority in writing. The Competent Authorities will try to resolve
the issue before any unilateral action, such as proposing an adjustment, is undertaken.
- A BAPA and the underlying Domestic APA may be revised at
any time by mutual agreement between the Competent Authorities after consultation
with the Associated Enterprises and receipt of their approval and acceptance
of such revision.
Section 7 LIMITATION ON THE USE OF TAXPAYER INFORMATION
- The PATA members acknowledge that problems can develop if
information obtained during the BAPA process is misused.
- Any information received or prepared by a PATA member in connection
with the pursuit of a BAPA, including information furnished by the Associated
Enterprises, or another Competent Authority, will be subject to the restrictions
on disclosure of taxpayer information provided for in the applicable domestic
law and Convention.
- For greater certainty, if the BAPA process requires the review
of sensitive or confidential information (such as a trade secret) that, if disclosed,
could harm a taxpayer’s competitive position, the Competent Authorities
will ensure all measures are taken to protect the confidentiality of the information
in accordance with Section 7.2.
Section 8 DOMESTIC PROCEDURES
Each PATA member should publish procedures for BAPAs.
Section 9 LANGUAGE
This guidance is to be published in English, French and Japanese, all texts
being equally treated.
Section 10 CONTACTS
Correspondence or exchanges of information under this guidance is to be made
to the addresses specified in Appendix E.
Section 11 MODIFICATIONS
This guidance may be modified at any time pursuant to consultations among
all PATA members.
APPENDIX A
Conventions
The Conventions referred to in Section 2.2 of this guidance are to the following
Income Tax Conventions entered into by PATA members, as amended from time to
time:
- Canada and the United States of America with Respect
to Taxes on Income and on Capital, which was originally signed in Washington,
D.C. on September 26, 1980, as amended by the Protocols signed on June 14, 1983,
March 28, 1984, March 17, 1995 and July 29, 1997.
- Australia and Canada for the Avoidance of Double Taxation and the
Prevention of Fiscal Evasion with Respect to Taxes on Income, which was originally
signed in Canberra, Australia, on May 21, 1980, as amended by the Protocol signed
on January 23, 2002.
- Canada and Japan for the Avoidance of Double Taxation and the Prevention
of Fiscal Evasion with Respect to Taxes on Income, which was originally signed
in Tokyo, Japan on May 7, 1986, as amended by the Protocol signed on February
19, 1999.
- Government of Australia and the Government of the United States
of America for the Avoidance of Double Taxation and the Prevention of Fiscal
Evasion with Respect to Taxes on Income, which was originally signed in Sydney,
Australia on August 6, 1982, as amended by the Protocol signed on September 27,
2001.
- Japan and the United States of America for the Avoidance of Double
Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income,
which was signed in Tokyo on March 8, 1971. Japan and the United States of America
for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with
Respect to Taxes on Income, which was signed in Washington D.C. on November 6,
2003.
- The Commonwealth of Australia and Japan for the Avoidance of Double
Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income,
which was originally signed in Canberra, Australia on March 20, 1969, as amended
by the Protocol signed on March 20, 1969.
Information in this Appendix was last updated on February 6, 2004.
APPENDIX B
Glossary of Terms
The definitions marked with an asterisk are from the 1995 Report to the OECD
Committee on Fiscal Affairs, “Transfer Pricing Guidelines for Multinational
Enterprises and Tax Administrations”.
Arm's Length Principle *
The international standard that OECD members have agreed should be used for
determining transfer prices for tax purposes. It is set forth in Article 9 of
the ‘OECD Model Tax Convention on Income and on Capital’ (the OECD
Model Tax Convention) as follows:
[where] conditions are made or imposed between the two enterprises in
their commercial or financial relations which differ from those which would be
made between independent enterprises, then any profits which would but, for those
conditions, have accrued to one of the enterprises, but, by reason of those conditions,
have not so accrued, may be included in the profits of that enterprise and taxed
accordingly.
Associated Enterprises *
Two enterprises are associated with respect to each other if one of the enterprises
meets the conditions of Article 9, subparagraph 1(a) or 1(b) of the OECD Model
Tax Convention with respect to the other enterprise, i.e.:
- a) an enterprise of a Contracting State participates
directly or indirectly in the management, control or capital of an enterprise
of the other Contracting State, or
- b)the same persons participate directly or indirectly in the management,
control or capital of an enterprise of a Contracting State and an enterprise
of the other Contracting State.
Bilateral Advance Pricing Arrangement (BAPA)
A BAPA is an arrangement, understanding, or similar undertaking between two
(2) Competent Authorities regarding the establishment, on a prospective basis,
of an acceptable and appropriate transfer pricing methodology (TPM) to be applied
to a cross-border transaction between Associated Enterprises, under specified
terms and conditions, for purposes of the applicable Convention.
Critical Assumptions
A Critical Assumption is any fact, the continued existence of which is material
to the taxpayer's proposed transfer pricing methodology (TPM) whether in respect
of the taxpayer, a third party, an industry, or business or economic condition.
The breach of a Critical Assumption will trigger the renegotiation or cancellation
of the BAPA even though the Critical Assumption may or may not be within the
control of the taxpayer. Critical Assumptions within the control of a taxpayer
include, for example, a particular mode of conducting business operations, or
a particular corporate or business structure. Critical Assumptions not within
the control of a taxpayer include, for example, a range of expected business
volume.
Domestic Advance Pricing Arrangement (Domestic APA)
A Domestic APA is an arrangement, understanding, or similar undertaking between
a PATA member and a taxpayer regarding the establishment, on a prospective basis,
of an acceptable and appropriate transfer pricing methodology (TPM) to be applied
to a cross-border transaction between Associated Enterprises, under specified
terms and conditions, for purposes of the applicable domestic law and Convention.
A Domestic APA is derived from a BAPA negotiated between Competent Authorities.
Unilateral Advance Pricing Arrangement (Unilateral APA)
A Unilateral APA is an arrangement, understanding, or similar undertaking
between a PATA member and a taxpayer regarding the establishment, on a prospective
basis, of an acceptable and appropriate transfer pricing methodology (TPM) to
be applied to a cross-border transaction between Associated Enterprises, under
specified terms and conditions, for purposes of the applicable domestic law.
A Unilateral APA does not result from negotiations between Competent Authorities.
APPENDIX C
BAPA Request
It is suggested that the following items be contained in a taxpayer’s
BAPA request. However, the PATA member should refer a taxpayer to domestic procedures
to ensure that all information required is provided.
- a) Name, address, nature of business and taxpayer identification
number of the Associated Enterprises;
- b) Proposed term of the BAPA and consideration for a roll-back to specified
prior years;
- c) Declaration by the taxpayer as to whether or not the years are open under
the statutes of adjustment in both of the PATA member countries and expiry dates,
if appropriate;
- d) Information regarding any related or relevant MAP process commenced in
the other country;
- e) Description of the proposed covered transaction;
- f) TPM proposed for the covered transaction and how it produces results consistent
with the Arm’s Length Principle;
- g) Contact person for the taxpayer;
- h) Authorization for a representative to act on behalf of the taxpayer; and
- i) Economic data or economic reports relied upon, explanatory narratives,
and taxpayer documents or records, e.g., details regarding comparable transactions
and, if required, adjustments performed to improve comparability.
APPENDIX D
Position Paper
It is suggested that the following items be contained in a PATA member’s
position paper:
- a) Name, address, nature of business and identification number
for the Associated Enterprises and the basis for determining the association;
- b) Description of the proposed covered transaction;
- c) Identification of the relevant functions, assets, and risks of the taxpayer(s)
in the PATA country(ies);
- d) TPM considered most appropriate for the covered transaction and a detailed
explanation of how it produces results consistent with the Arm’s Length
Principle;
- e) Economic data or economic reports relied upon, explanatory narratives,
and taxpayer documents or records, e.g., details regarding comparable transactions
and, if required, adjustments performed to improve comparability; and
- f) Notification of the obligation to maintain the confidentiality of the
paper under the applicable Convention.
APPENDIX E
Communication
Communication or exchange of information under this guidance is to be made
to the following addresses:
Mr. Paul Duffus
First Assistant Commissioner
International Strategy and Operations
Competent Authority
Australian Taxation Office
PO Box 900, Civic Square
Canberra ACT 2608
Australia
Mr. Jim Gauvreau
Director
Competent Authority Services Division
International Tax Directorate
Canada Customs and Revenue Agency
5th Floor, Canada Building
344 Slater St.
Ottawa, Ontario
Canada, K1A OL5
Mr. Takeo Shikado
Deputy Commissioner
National Tax Agency
Ministry of Finance
1-1 Kasumigaseki 3-chome
Chiyoda-ku, Tokyo 100-8978, Japan
Mr. Robert H. Green
Director, International
Internal Revenue Service
Department of the Treasury
1111 Constitution Avenue N.W.
Washington, D.C. 20224
U.S.A.
Information in this Appendix was last updated on February 6, 2004.