Published on 01 Mar 12
by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE
The Commonwealth Government has announced proposals to reform Australia’s domestic transfer pricing rules contained in Div 13 of the Income Tax Assessment Act 1936. These rules deal with the tax treatment of cross-border transactions between related parties. A consultation paper has been released which outlines the broad principles upon which any change may be based. The stated aim of the proposed reforms is to better align our domestic transfer pricing rules with international best practice and the domestic rules of Australia’s major trading and treaty partners.
This article summarises the key elements of the reforms canvassed in the consultation paper, and provides a discussion of the practical implications arising from the reforms. The article notes that the review is timely, given the uncertain environment within which the rules currently operate. The reforms seek to eliminate some of this uncertainty by aligning the new legislation with Art 9 of the OECD Model Tax Convention and the OECD guidelines.
Soulla is a Transfer Pricing Partner with Deloitte.
Current at 30 April 2008
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Marc works for the ATO. He has been a Transfer Pricing Specialist for the last 17 years, including eleven years with ATO and six years with Deloitte. Marc is the author of several ATO transfer pricing rulings.
Current at 11 March 2009
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Leesan is a Manager with Deloitte.
Current at 1 March 2012