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Basics of transfer pricing documentation


Transfer pricing is an important issue for multinational companies that operate in Australia. Not only has the Australian Government been a vocal advocate for change and increased transparency, it has also sought to lead by introducing significant new and aggressive changes in local tax rules, both from a corporate tax and transfer pricing/avoidance perspective and from a goods and services tax perspective. This article examines the objective of transfer pricing documentation (TPD), the history of TPD in Australia (in particular, Div 13 and Divs 815-B and 815-C), and the steps in preparing TPD. This article also looks at the analysis of global group and local entity, and related-party dealings, including market and industry overview, functional and risk analysis, transfer pricing methodology, comparative benchmarking study and the implications of holding TPD, including disclosure in tax returns and risks to ATO review/penalties.

Author profile

Ashish Dave
Ashish Dave joined Duff & Phelps in May 2017 from Quantera Global. He is a director in the Transfer Pricing practice based in Sydney. Ashish has more than 15 years experience in international tax, specialising in transfer pricing. He has worked in a variety of locations such as Australia and Asia, including India. As a transfer pricing specialist, Ashish has advised a wide range of clients in preparing transfer pricing policies, designing transfer pricing systems, and documentation covering master file and local file. - Current at 25 June 2018
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