Australia’s new transfer pricing landscape
Tax event | 16 October 2013
Australia’s new transfer pricing legislation - what does it mean for you and how can you manage your risk?
We are delighted to invite you to our next Transfer Pricing insights event. This is a regular forum we conduct to provide insights on current transfer pricing topics relevant to your business.
Australia’s transfer pricing landscape has changed dramatically over the past year. As you will be aware, we now have new transfer pricing legislation which applies for income years commencing on or after 1 July 2013. The enactment of the new transfer pricing 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 operating in Australia.
In light of the uncertainty around the ATO’s enforcement of the new transfer pricing laws, and the ATO’s increased scrutiny of multinationals’ tax structures and transfer pricing practices, you need to understand how the new laws apply to your company and consider what steps to take to prepare for the possibility of future ATO transfer pricing reviews.
To help you identify and manage your transfer pricing risks in the current environment, we will discuss:
From a practical perspective, we will also share some insights in relation to the International Dealings Schedule (which the ATO has been actively using to identify taxpayers for further review), and provide an update from a tax controversy perspective given our recent experience on transfer pricing audit cases with the ATO. This will include an outline of what information and documentation the ATO expects taxpayers to have on hand, how the ATO approaches the task of rating your transfer pricing documentation, and what types of information can be discoverable in a risk review or audit context.
We hope you are able to join us for this session and encourage you to RSVP early as places are limited.
If you have any queries, please contact;