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Transfer Pricing - current issues and recent developments

Published on 16 Sep 2004 | Took place at City West Function Centre, West Perth , WA

A recent global survey of multinational enterprises and tax administrations identified that the vast majority of both parent and subsidiary respondents believe that transfer pricing is the most important international tax issue that they currently face.

While transfer pricing has long been the focus of the tax authorities in Australasia, Japan, Western Europe and North America, the pace of global development has led to increasing scrutiny in other countries. In the Asia-Pacific region, the last few years have seen significant developments in transfer pricing laws in China, India, Indonesia, Malaysia and Thailand. This is likely to lead to taxpayers being caught in the middle as tax authorities try to protect or expand their tax base.

These seminar materials address the importance of compliance with the transfer pricing legislation both in Australia and overseas.

Individual sessions

Transfer Pricing - current issues and recent developments

Author(s):  Ross LYONS,  Paul FIELDS This paper addresses the importance of compliance with the transfer pricing legislation both in Australia and overseas. Issues covered include:
- setting of transfer prices and methodologies
- Schedule 25A and the ATO's approach to compliance
- current ATO focus issues, including intellectual property and reduced-risk structures
- use of advance pricing arrangements, and PATA's recent guidance on bilateral APAs
- foreign currency fluctuations
- OECD 'hot topics'.

Materials from this session: