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Transfer Pricing - Schedule 25A

Published on 01 May 2008 | Took place at Kooyong Tennis Club, Melbourne, VIC

As part of their annual tax return Australian companies with related party transactions are required to disclose details surrounding their dealings with international related parties on the Schedule 25A. The Schedule is used by the ATO as a key part of its transfer pricing risk profiling and risk assessment activities.

The ‘first step’ in the ATO’s transfer pricing compliance activities comprises a comprehensive desk-based risk profiling exercise relying heavily on data provided by companies as part of their Schedule 25A disclosures. The form of companies’ responses to specific questions on the Schedule 25A can influence the ATO’s assessment of the relative level of transfer pricing risk at the company level.

This practical session explained how the ATO uses the Schedule 25A in its transfer pricing risk profiling activities, and gave practical tips on how to complete the Schedule.

Individual sessions

Transfer pricing: Schedule 25A

Author(s):  Soulla MCFALL,  Michael JENKINS,  Peter FAULL

This presentation covers:

  • when should a Schedule 25A be completed?
  • which transactions need to be included on the Schedule 25A?
  • how are transactions appropriately characterised, ie which labels?
  • what information is required to complete the Schedule 25A?
  • how does the ATO use the information contained in the Schedule 25A?
  • practical guidance on how the ATO views responses to specific questions in the Schedule
  • what is transfer pricing documentation?
  • what is the ATO's 4-step process?
  • what are the commonly used transfer pricing methodologies?
Materials from this session: