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Self-assessment update: Draft transfer pricing documentation, penalties & reconstruction guidance from the ATO paper

Published on 05 Aug 14 by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • new transfer pricing documentation requirements – subdivision 284-E TAA 1953
  • penalties – overview of PS LA 3672
  • the Commissioner’s broader powers of reconstruction – overview of TR 2014/D3
  • what should taxpayers do in this environment?

Author profile:

Janelle Sadri
Janelle is an Account Director in the Deloitte Perth transfer pricing practice. Janelle has over 7 years of experience in both corporate/international tax and transfer pricing. Janelle has advised on several significant inbound and outbound structuring projects in the natural resources sector, including finance structuring and debt pricing to support arm’s length gearing / interest levels, and business restructures involving the movement of key profit driving functions and the migration of intellectual property. Janelle has provided advice in relation to the interpretation and application of the arm’s length principle in an MRRT and PRRT context. Janelle has also project managed and successfully negotiated unilateral and bilateral Advance Pricing Arrangements (APAs), delivered regional/global transfer pricing planning and documentation studies, and has assisted clients in transfer pricing risk reviews and audit settlements. Janelle has published articles on transfer pricing issues in Asia Pacific journal
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This was presented at International Tax Day.

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