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Offshoring or exporting - The ATO's approach to your cross-border transactions with related parties paper


Increasingly, Australian businesses are setting up operations offshore to reduce costs, especially in the Asian region. As businesses start to deal with related overseas parties, they are becoming subject to closer ATO attention due to the perceived risks to the Revenue. The ATO’s compliance activities for the SME market are now focusing on cross-border transactions, and in particular transfer pricing is being examined for smaller business. Recent developments mean now is the time for advisers to consider what kind of transactions are likely to attract ATO attention, and help their clients understand the implications and compliance requirements that follow.

This paper covers:

  • the reform of Australia’s transfer pricing laws
  • key focus areas in transfer pricing, eg business restructures, financing, IP and the internet/cloud
  • permanent establishments
  • transfer pricing documentation and tax return disclosures.

Author profile

Frank Putrino ATI
Frank is a Director in KPMG's Global Transfer Pricing Services practice in Melbourne and has over 23 years of transfer pricing and international tax experience across both industry and professional service firms. As the former in-house Global Transfer Pricing Director & Counsel for a Fortune 100 MNC for 9.5 years, Frank was responsible for the design, development and implementation of transfer pricing strategy, policy, processes and documentation and controversy across the Americas, Europe and Asia Pacific regions. Prior to that, Frank was a Principal in a Professional Services Transfer Pricing team for 12.5 years. Frank has assisted a number of Australian and overseas based clients with their transfer pricing and global supply chain planning, compliance and controversy needs by bringing a wealth of operational and tax experience applied across diverse industries and jurisdictions. His experiences balance and recognize the synergies required among the business and tax teams, resulting in practical, commercial strategies that provide viable transfer pricing solutions to complex business challenges. - Current at 14 August 2013
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This was presented at 46th South Australian Convention .

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Individual sessions

SME risk differentiation framework

Author(s):  Scott BRYANT,  Michael CRANSTON

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