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The role and design of a transfer pricing risk assessment framework for tax administrators


Transfer pricing has become one of the most important contemporary international tax issues. Transfer pricing risk assessment is a critical issue for all tax administrations to identify the right cases to audit and subsequently impose an appropriate level of transfer pricing enforcement in the event of non-compliance with relevant transfer pricing rules.

This article will provide an overview of transfer pricing issues and examine reasons why transfer pricing risk assessments play a significant role in tax administration. Based on the approach suggested by the Organisation for Economic and Co-operation and Development, a discussion of which factors should be considered when conducting transfer pricing risk assessment will be undertaken. A number of recommendations for designing procedures and methods for the assessment will also be made for developing countries drawing from the experience of developed countries where transfer pricing risk assessment procedures have already effectively been implemented.

Author profiles

Thu Ha Le Thi
Thu Ha Le Thi, Tax Inspector in Vietnam, Former Student of Master in Taxation, Curtin University.
Current 1 June 2016
Prof Dale Pinto CTA-Life
Photo of author, Dale PINTO Dale Pinto is currently a Professor of Taxation Law in the Curtin Law School at Curtin University. He is the 2018 President of the Divisional Council of CPA Australia (WA Division) and is also a Fellow of CPA Australia, a Fellow of the Australian Academy of Law and is a Chartered Accountant, Chartered Tax Adviser and Life Member of the Tax Institute. Dale is the author/co-author of numerous books, refereed articles and national and international conference papers, and is on the editorial board of a number of peer-reviewed journals as well as being the Editor-in-Chief of several refereed journals. Dale is the Chair of the Tax Institute's National Education Quality Assurance Board and is a member of TEQSA's Expert Panel in Accounting and Taxation. Dale served as an inaugural member of the National Tax Practitioners Board and is a current member of the Board of Taxation's Advisory Panel and the ATO's Tax Technical Panel (Superannuation), as well as the Tax Institute's Technical Committees (Superannuation, Not-for-Profit Organisations and Large Business and International). - Current at 16 February 2018
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Colleen Mortimer CTA
Study Period 1 2017 CTA1 - Subject Lecturer - Lecture 1: Calculating Tax Payable and Assessable Income and Lecture 3: Structures CTA2A - Subject Webinar Presenter - Webinar 3: Partnerships & Webinar 4: Trusts Colleen has been a lecturer at Curtin University since 1988. She currently teaches in a number of postgraduate tax units and has won many awards for her teaching. Prior to joining Curtin University she worked at the Australian Taxation Office and Arthur Andersen and operated her own business specialising in small businesses. Colleen is also a Senior Manager at BDO where she is responsible for the Learning and Development in both the Corporate and International tax area and the Private Clients area. She also teaches for the Tax Institute in both the CTA1 Foundations and CTA2A Advanced subjects. - Current at 26 June 2017
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