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 Current at 27 April 2009
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