Comment on PATA Guidance for bilateral APAs

The authors evaluate and comment on the recently released PATA Guidance on bilateral advance pricing agreements. This APA Guidance is an attempt by the tax authorities to provide a common framework for taxpayers and tax authorities regarding the process of applying for and negotiating a bilateral advance pricing agreement. The authors give an overview of the guidelines, the status of APAs in various PATA countries (Australia, Canada, Japan and the United States), and present their conclusion on the usefulness of this PATA Guidance