Important: Reset your password We've made some changes to our website. You will need to reset your password to access your account, access online books, purchase items from our online shop, or download papers from the Tax Knowledge eXchange.
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 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
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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.
We've made some changes to our website. You will need to reset your password to access your account, access online books, purchase items from our online shop, or download papers from the Tax Knowledge eXchange.
To reset your password, click on 'Reset password' below.