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Legislative changes to the transfer pricing rules - The state of play paper

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.

It covers:

  • 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.

Author profile:

Author Photo - Geoff GILL
Geoff GILL
Geoff is a partner and senior economist with Deloitte’s Global Transfer Pricing group in Sydney. Geoff’s key focus area is the financial services industry including transfer pricing issues associated with debt funding, and he has published a number of articles and spoken at external seminars in this area.
Current at 18 November 2008 Current at 27 April 2009 Click here to expand/collapse more articles by Geoff GILL.
 

 

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Legislative changes to the transfer pricing rules - The practical implications

Author(s):  Tony Gorgas

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