Transfer pricing Miscellaneous 2019

SME and private clients: Transfer pricing outside the top 1,000

Source: The Tax Specialist Journal Article

Published Date: 1 Oct 2019


The ATO has focused significant resources and attention in recent years to managing transfer pricing risk through large corporate assurance programs and the release of risk guidance through practical compliance guidelines, tax determinations and tax alerts. In the authors' view, this approach is aimed at managing the tax risk of large businesses. As large businesses provide a significant portion of tax in Australia, the ATO's focus on gaining assurance that these entities are paying their fair share of tax is not unexpected. However, it seems that the ATO has ignored, or is unaware of, the unintentional consequences that this focus has had on managing transfer pricing risk in the small-to-medium enterprise (SME) business segment. This article identifies transfer pricing considerations and challenges currently faced by SMEs and outlines the ATO's evolving approach to dealing with the transfer pricing arrangements of SMEs.

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Transfer pricing Miscellaneous 2019

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