08 Mar 07 Income tax: international transfer pricing - TR 2007/1This final Taxation Ruling was issued on 7 March 2007. It was not previously released in draft form. Its full title is "Income tax: international transfer pricing: the effects of determinations made under Division 13 of Part III of the Income Tax Assessment Act 1936, including consequential adjustments under s 136AF of that Act".
The Ruling explains the effects on taxpayers of a determination made under the provisions of Division 13 of Part III (Division 13) of ITAA 1936 in relation to non-arm's length schemes.
On 7 March 2007, as a result of the issue of TR 2007/1, the ATO withdrew TR 1999/8 (Income tax: international transfer pricing: the effects of determinations made under Division 13 of Part III, including consequential adjustments under s 136AF) with effect from the same day.
The ATO states in the Notice of Withdrawal that the views expressed in TR 1999/8 are no longer current. To the extent that the views in TR 1999/8 still apply, they have been incorporated in Taxation Ruling TR 2007/1. TR 1999/8 can continue to apply to schemes that had begun to be carried out before 7 March 2007.
For a copy of TR 2007/1, go here
For a copy of TR 1999/8W, go here