Transfer pricing Miscellaneous 2017

Transfer pricing in practice for smaller enterprises

Source: The Tax Specialist Journal Article

Published Date: 1 Jun 2017


Unlike larger enterprises which have the budget and the people in-house to devote to complex transfer pricing issues, small-to-medium enterprises (SMEs) may not. Small-to-medium enterprises are faced with the dual challenge of understanding new technical issues and paying, in terms of time and dollars, to implement new compliance processes.

This article provides a summary of Australia's transfer pricing and related documentation rules as they apply to SMEs. The author analyses in detail how the international dealings schedule and local transfer pricing documentation supporting the tax return lodged need to tell the same story; how penalty reduction is now linked to recommended transfer pricing documentation that presents a reasonably arguable position; how new ATO administrative practices under simplified record-keeping concessions reduce the size and cost of transfer pricing documentation; how self-assessment puts the onus on the taxpayer to lodge a correct tax return and the new country-by-country regime and separate lodgment processes that may cause smaller enterprises to be encompassed into yet more compliance burden.

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Transfer pricing Miscellaneous 2017

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