Published on 01 Oct 19
by "THE TAX SPECIALIST" JOURNAL ARTICLE
The ATO has focused significant resources and attention in recent years to managing transfer pricing risk through large corporate assurance programs and the release of risk guidance through practical compliance guidelines, tax determinations and tax alerts. In the authors’ view, this approach is aimed at managing the tax risk of large businesses. As large businesses provide a significant portion of tax in Australia, the ATO’s focus on gaining assurance that these entities are paying their fair share of tax is not unexpected. However, it seems that the ATO has ignored, or is unaware of, the unintentional consequences that this focus has had on managing transfer pricing risk in the small-to-medium enterprise (SME) business segment. This article identifies transfer pricing considerations and challenges currently faced by SMEs and outlines the ATO’s evolving approach to dealing with the transfer pricing arrangements of SMEs.
Aileen O’Carroll is Partner/Executive
Director in the Tax Consulting division of
Pitcher Partners Melbourne and heads up
the firm’s transfer pricing service offering.
Aileen has over 12 years consulting
experience providing advice on a broad
range of transfer pricing matters to clients
across a range of different industries.
Prior to joining Pitcher Partners in 2016,
Aileen worked with the National Australia
Bank in assisting them to implement
OECD Action 13 – Country by Country
(“CbC”) Reporting. During this time, Aileen
worked extensively with a wide range of
stakeholders globally and domestically. She
established an Action 13 working group with
industry peers and also consulted regularly
with the ATO on CbC, which included
development of the Australian Local File.
She has also worked with KPMG UK and
Australia for 10 years in the transfer pricing
practice, advising clients on transfer pricing
matters, including financing arrangements,
business restructures, risk review, audit
defense assistance, implementation and
operationalisation of transfer pricing
policies and putting in place transfer
- Current at
27 August 2018