Published on 23 Oct 13
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
The recently enacted Cross Border Transfer Pricing legislation imposes a higher obligation on Public Officers of companies to maintain appropriate TP documentation on a contemporaneous basis to defer and defend ATO investigation. Cross border financing, business restructures and profit based assessments where a business has consistently low profits or losses are likely ATO targets.
This practical paper provides guidance on how to develop a framework to adapt to this new TP environment including:
ensuring your company’s TP documentation meets the ATO requirements of a reasonably arguable position to avoid automatic penalties should an audit adjustment arise
impact on IDS disclosure and your company’s risk profile
limitation on period for ATO to amend
personal liability of public officers for penalties arising from a false or misleading statements related to TP.
John has been advising on tax issues for over 30 years and has considerable experience in advising clients on a broad range of tax issues including tax efficient structuring for investing in and out of Australia, corporate reorganisation strategies and cross-border employment issues. John has been a tax director in five countries and brings his extensive international experience to assist clients in expanding their Australian operations overseas. He specialises in transfer pricing assignments for Pitcher Partners’ corporate clients. Current at 23 October 2013
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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