This site uses cookies to provide you with a more responsive and personalised service. By using this site you agree to our use of cookies. Please read our cookie notice for more information on the cookies we use and how to delete or block them.

Bookmark Email Print page

The Benchmark archive

The Benchmark

November 2011
  • Latest news on OECD project on transfer pricing aspects of 'intangibles'
  • Joint seminar by ATO and Japan NTA highlights good working relationship on transfer pricing
  • ATO releases draft International Dealings Schedule and instructions.
September 2011
  • The ATO approach to commercial realism: time for a rethink?
  • New ATO paper on profit allocation to bank branches
July 2011
  • New ATO Reportable Tax Position schedule
  • ATO released 2011-12 compliance program
  • The SNF case: where to now?
May 2011
  • The effects of the rising Australian dollar on your transfer prices
  • New OECD project on administration of transfer pricing.
April 2011
  • Transfer pricing implications of proposed changes to Controlled Foreign Company (CFC) rules
  • National Tax Liaison Group (NTLG) Transfer Pricing Sub-group update
  • The SNF case appeal.
March 2011
  • APAs given new life in Australia
  • ATO commences first transfer pricing "Joint Audits"
  • OECD releases scoping document for its intangibles project.
February 2011
  • Taxation Ruling TR2011/1
  • Business Restructuring: no changes from the ATO.
December 2010
  • ATO's Strategic Compliance Initiative
  • Business restructures
  • The ATO's focus on financial arrangements
  • Transfer pricing litigation – the SNF Australia case
  • International dealings schedule.
November 2010
  • Latest ATO developments
  • Australian APA program booming
  • New domestic arm's length dealing rule for MITs
  • Global.DoX.
October 2010
  • OECD to revise guidance on intangibles
  • ATO update on transfer pricing for large business
  • Industry data used by ATO to assess transfer pricing risk
  • Application of the arm's length principle to the minerals resource rent tax.
September 2010
  • Is the TNMM still a viable approach for taxpayers in Australia?
  • Update on the ATO's strategic compliance initiative
  • Update on the ATO's 'rule of thumb' approach to the pricing of inbound intra group loans
  • China developments – transfer pricing documentation inspections and business restructures.
August 2010
  • OECD Guidelines receive a facelift
  • NTLG developments
  • Transfer pricing remains a major area of focus in the ATO's compliance program
  • Welcome back Marc Simpson.
July 2010
  • Profit-based methods sidelined again by Australian court
  • Revised ruling on pricing of international financing arrangements
  • Transfer pricing flagged by ATO as key compliance risk.
June 2010
  • ATO ruling on business restructures
  • Spotlight on transfer pricing developments in China
  • GE Capital case – grounds of appeal explored.
May 2010
  • Government's response to Henry Review will do little to improve Australia's competitiveness
  • ATO consults on an alternative 'rule of thumb'
  • Moving towards a higher level of global cooperation
  • Introducing Jonathon Bernsen - another new Transfer Pricing partner for Deloitte!
April 2010
  • GFC impact on profit benchmarking
  • The latest from the ATO on transfer pricing matters
  • Spotlight on transfer pricing documentation requirements in Japan
  • Introducing Bill Yohana.
March 2010
  • Resources sector is the latest ATO target
  • Tough times ahead for taxpayers with 'uncertain tax positions'
  • Are you prepared for a transfer pricing audit in China?
  • Transfer pricing still on the radar in Europe.
February 2010
  • Strategic Compliance Initiative - ATO's transfer pricing project
  • Financing - intra group loans and guarantee fees
  • Draft Taxation Ruling TR 2009/D6 - interaction of thin capitalisation and transfer pricing provisions
  • Rule of thumb PS LA 3187
  • Final international dealing schedule reflects feedback from industry and professional bodies
  • Deloitte partners listed as Australia's leading transfer pricing advisers.
December 2009
  • ATO's Strategic Compliance Initiative – 140 transfer pricing questionnaires to be sent in the new year
  • Further ATO commentary on intra-group financing due later this month
  • GE Capital Canada wins guarantee fee case
December 2009
Special Edition
  • Draft taxation ruling - TR 2009/D6
  • Draft practice statement - PS LA3187
November 2009
  • ATO to issue Practice Statement on 'Rule of thumb' approach for pricing of intra-group loans
  • Guarantees within multinationals – a timely visit to Australia for global expert
  • LBAG continue the debate on draft international dealings schedule
  • ATO crackdown on employee share scheme recharges
October 2009
  • ATO begins revised risk assessment approach by collecting new information
  • OECD elevates status of profit-based methods
  • ATO releases 2008-09 APA Program, with commentary on the global financial crisis 
  • New accounting standard requires certainty on transfer pricing.
September 2009
  • Are you prepared for the ATO?
  • Australian transfer pricing litigation update
  • Chinese tax authorities focus on losses 
  • Welcome Jacques Van Rhyn
August 2009
  • Commissioner of Taxation addresses - Deloitte's Tax perspective event
  • 'Rule of thumb' proposal for pricing of intra group loans
  • New Australia - New Zealand tax treaty
  • New ATO International Dealings Schedule
July 2009
  • ATO steps up investment in APA program
  • Maximising fiscal gains & shareholder returns: ATO announcements
  • Highlight conflicts in a common goal
  • OECD holds consultation with business on restructuring
  • Commentary on double taxation relief indicative of Hong Kong's ambitions?
June 2009
  • A "Transfer Pricing Review" of the Australian federal budget: against the backdrop of the Henry review and the current global transfer pricing landscape
  • Welcome news on unlimited amendment periods
  • ATO's Transfer Pricing consultative committees
May 2009
  • Transfer pricing for financing – more than LIBOR plus a margin?
  • BHP Billiton Finance Limited v Federal Commissioner of Taxation
  • New Zealand's IRD announces focus on issues arising from recent economic events
April 2009
  • Deloitte's response & public comments on the OECD's business restructures paper
    – risks and opportunities in an economic downturn
  • New Zealand's IRD announces increased focus on related-party IP licensing transactions
  • The Guardian investigation of multinationals
  • Carbon Pollution Reduction Scheme – international linking opportunities
March 2009
  • Transfer pricing - risks and opportunities in an economic downturn
  • The ATO's response
  • Short-term strategies
  • Medium to longer term-planning
February 2009
  • Decision Impact Statement: ATO views on the Roche case
  • IRS releases proposed and temporary cost share regulations
  • China developments - thin capitalisation rules and documentation requirements
  • ATO's APA program review – update
December 2008
  • Transfer pricing in the courts
  • Policy developments
  • Transfer pricing on the ATO's radar again
  • Looking ahead . . .
November 2008
  • Advance pricing arrangement (APA) program review
  • The credit crisis and debt pricing
  • ATO to set up SME compliance activities
  • Transfer pricing rules allow shifting of business losses to Australia.
October 2008 
  • Transfer pricing matter before the Federal Court
  • transfer pricing at the OECD
  • Deloitte's global financial services industry expert in Australia 
  • China issues new Circular regarding intercompany services.
September 2008 
  • OECD releases draft discussion paper on business restructures
  • ATO continues its focus on use of trust arrangements by partnerships
  • Asian governments continue to step up their enforcement of transfer pricing.
August 2008 
  • High Court releases its judgment in WR Carpenter
  • Singapore introduces transfer pricing reviews
  • OECD approves 2008 update to the Model Tax Convention
  • facts and figures.
August 2008 - special edition 
  • ATO released Annual Compliance Program statement for the 2008-09 fiscal year
June 2008 
  • GlaxoSmithKline in Canada – transactional methods again
  • GE Canada – judgment relevant to commercial purpose and transfer pricing
  • new Schedule 25A 2008 form released by the ATO
  • facts and figures.
June 2008 - special edition 
  • ATO discussion paper – intra-group finance guarantees and loans
  • specific issues.
May 2008 
  • ATO discussion draft on debt pricing and guarantee fees
  • annual compliance arrangements
  • IRS APA procedure now covers permanent establishments and other issues
  • facts and figures.
April 2008
  • Roche case – further considerations
  • National Tax Liaison Group (NTLG) transfer pricing sub-group meeting
  • ATO discussion paper on debt pricing and guarantees
  • facts and figures.
  • judge rules transfer pricing adjustments for an Australian distributor of a large foreign owned MNC of A$58M
  • background
  • the preliminary judgement
  • transfer pricing analysis – not just a valuation exercise
  • tips & takeaways.
March 2008 
  • draft TD regarding interaction of Division 974 and Division 13
  • the competent authority process
  • US IRS releases paper on cost-sharing stock-based compensation
  • facts and figures.
February 2008 
  • new Chinese transfer pricing rules – effective 2008
  • new Australia-Japan tax treaty
  • withdrawal of ATOID – foreign branch transactions and the single entity rule
  • facts and figures.
January 2008 
  • ATO and business restructures – in the news again
  • transfer pricing priorities in New Zealand in 2008
  • guarantee fees – another case in Canada
  • facts and figures.
January 2008 - new year edition 
  • Deloitte workshop on guarantee fees and related financing issues
  • summary of the Benchmark: July – November 2007
  • facts and figures.
November 2007 
  • revised OECD discussion draft on attribution of profits to permanent establishments (PEs) in the insurance industry
  • APA program review – update
  • interaction of Australia's thin capitalisation and transfer pricing provisions – issue of a draft Taxation Determination
  • customs and transfer pricing
  • facts and figures.
October 2007 
  • improvements in process for relief from double taxation
  • ATO annual advance pricing arrangement (APA) program update
  • external review of the advance pricing arrangement (APA) program
  • facts and figures.
September 2007
  • intercompany loan guarantees – a wave of controversy looming?
  • review of unlimited amendment periods for transfer pricing
  • ATO releases fifth annual report on APA program
  • facts and figures.
August 2007
  • ATO's business restructuring discussion paper
  • FIN 48 developments
  • Keith Reams joins the Australian Deloitte team
  • facts and figures.
August 2007 - special edition
  • transfer pricing and the 2007-08 ATO compliance program
  • facts and figures.
July 2007
  • transfer pricing – renewed focus on global restructures and foreign bank branches in Australia
  • 2007 Schedule 25A released
  • David Grecian joins Deloitte
  • facts and figures.

Page Last Updated


Follow us


Talk to us