Transfer pricing 2012

Transfer pricing reforms in Australia

Source: Taxation In Australia Journal Article

Published Date: 1 Mar 2012

 

The Commonwealth Government has announced proposals to reform Australia’s domestic transfer pricing rules contained in Div 13 of the Income Tax Assessment Act 1936. These rules deal with the tax treatment of cross-border transactions between related parties. A consultation paper has been released which outlines the broad principles upon which any change may be based. The stated aim of the proposed reforms is to better align our domestic transfer pricing rules with international best practice and the domestic rules of Australia’s major trading and treaty partners.

This article summarises the key elements of the reforms canvassed in the consultation paper, and provides a discussion of the practical implications arising from the reforms. The article notes that the review is timely, given the uncertain environment within which the rules currently operate. The reforms seek to eliminate some of this uncertainty by aligning the new legislation with Art 9 of the OECD Model Tax Convention and the OECD guidelines.

Author Profile
Soulla Mcfall

Author Profile
Marc Simpson

Author Profile
Leesan Mcleish

Sorry, this is subscriber only content.

To gain access to this material and much more - Subscribe Now.

(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).

Already a Subscriber? Login now

Details

The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))

("TTI")

The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.

Tags

Transfer pricing 2012

Share this page