Deloitte response to Australia’s transfer pricing landscape
Australia’s transfer pricing landscape has changed dramatically. The enactment of new transfer pricing laws (the new laws) – part of the biggest overhaul of Australia’s transfer pricing rules for 30 years – has been accompanied by the ATO’s establishment of a new anti-profit-shifting taskforce and notification of a significant increase in ATO investigations of multinational corporations (MNCs) operating in Australia.
Uncertainty around the ATO’s enforcement of the new laws, coupled with increased ATO scrutiny of MNCs’ tax structures and transfer pricing practices, means that MNCs need to understand how the new laws apply to them and consider what steps to take to prepare for the possibility of future ATO transfer pricing review.
What does it mean for you? How should businesses respond?
The attachment above comments on key features of the new laws, the new ATO taskforce, the substantial increase in profit-shifting risk reviews and audits flagged by the ATO, and identifies some important practical considerations arising from the new laws’ operation.
Our comments are focused on what is different under the new laws, including what practical measures taxpayers should take to respond to the changing transfer pricing environment in this country.