June 25, 2004
National Tax Agency
The Pacific Association of Tax Administrators (PATA) issued internal operational guidance in respect of mutual agreement procedures (MAP) and bilateral advance pricing arrangements (BAPA). PATA is comprised of representatives from the tax administrations of Australia, Canada, Japan, and the United States.
The first document is entitled “MAP Operational Guidance for Member Countries of the Pacific Association of Tax Administrators”. The purpose of this document is to facilitate and support resolution of MAP cases among PATA members as well as to ensure consistent and timely treatment of such cases.
The second document is entitled “BAPA Operational Guidance for Member Countries of the Pacific Association of Tax Administrators”. The purpose of this document is to establish a common approach for treating taxpayers in a fair and consistent manner when seeking a 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 PATA members.
The purpose of releasing these internal working documents is to increase the level of transparency in the MAP and BAPA processes within PATA member countries.