Published on 18 Sep 13
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
Australian transfer pricing laws have undergone their most radical change in 30 years and it will impact every Australian multinational. This paper provides an overview of the background and drivers for the legislative changes, and an overview of the key changes and implications for MNCs.
- background and drivers for change in the Australian transfer pricing legislation
- relevance and interaction between Division 13, s815-A and the new s815-B and s815-C laws
- key aspects of the new legislation, including application of the arm’s length principle, relevance of economic substance and ATO reconstruction powers, and requirements for transfer pricing documentation
- implications for MNCs historical and future transfer pricing positions
- treaty partner considerations and dispute resolution mechanisms.
Geoff is a transfer pricing partner with Deloitte based in Sydney. Geoff leads Deloitte Australia's transfer pricing practice for the financial services industry and also specialises in the analysis of financial transactions. He has advised on many APAs, audits and risk reviews including the first completed joint transfer pricing audit between the ATO and IRS. Recently, Geoff has been closely involved in working with the Australian Treasury on the reforms to Australia's transfer pricing rules.
- Current at
01 November 2013