Advance Pricing Arrangements (APAs)

Key requirements

A unilateral APA involves IRAS and the taxpayer; bilateral and multilateral arrangements involve one or more treaty partner authorities. A unilateral arrangement does not bind the foreign authority, so cross-border certainty can be lower. Where no DTA exists, the unilateral route falls under the advance ruling framework with a fee; the page distinguishes the no-fee route where a DTA exists. APA applications can require significant resources and are most relevant where value or risk is material. A transaction under litigation should normally proceed through one route, with court proceedings suspended if the APA request is accepted in the described circumstances. Consider the covered period, assumptions and foreign tax treatment before choosing the arrangement.