10 Feb 11 Transfer pricing and business restructuring by multinational enterprises - TR 2011/1
On 9 February 2011, the ATO issued final Taxation Ruling TR 2011/1 entitled "Income tax: application of the transfer pricing provisions to business restructuring by multinational enterprises". It was previously released in draft form. as TR 2010/D2.
The Ruling set outs the Commissioner's views on the application of Australia's transfer pricing provisions in Division 13 of Part III (Division 13) of ITAA 1936 and the Associated Enterprises Article of Australia's tax treaties (treaty Article 9) of the International Agreements Act 1953 (Agreements Act) to business restructuring arrangements.