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 presentation 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.