This paper discusses Australia’s transfer pricing landscape and the ATO’s focus on transfer pricing and profit shifting. Specifically, it offers:
- an overview of Australian transfer pricing reforms over the past 18 months, and the local / global (OECD) focus on profit shifting and base erosion
- discussion on both the technical aspects and key practical implications of Australia’s new transfer pricing rules for taxpayers
- hot topics / focus areas for revenue authorities (e.g. business restructures, financing, intangible property, (marketing) services transactions)
- an update in terms of the ATO’s transfer pricing compliance enforcement activity – including the International Dealings Schedule, risk reviews and audits.