Transfer pricing remains one of the key issues for multinationals with an ongoing focus from the ATO its many review or assurance programs.
This paper discusses some of the insights from recent ATO reviews on TP matters and how tax teams can practically manage TP risk in their organisation.
In addition, it will consider how the other recent tax law changes (such as the proposed thin capitalisation changes and the related party payments in relation to intangibles) can impact TP and what additional TP considerations taxpayers should focus on.