Is Subdiv 815-B on transfer pricing overly prescriptive?
Source: The Tax Specialist Journal Article
Published Date: 1 Aug 2015
Australia's domestic transfer pricing laws underwent two waves of reform in recent years. While judicial decisions and administrative developments acted as an impetus for change, interim amendments introduced retrospectively in the first tranche of reforms were but only a stopgap measure. This article focuses on the second tranche of reforms in 2013, which brought in a detailed and prescriptive framework on transfer pricing. As one awaits judicial direction on how the new legislation is to be applied, it remains to be seen whether the objectives of modernising transfer pricing rules and aligning them with international best practice could be achieved and whether, in light of the recent base erosion profit shifting developments, further changes are necessary.
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Details
- Published By: Cindy Chan
- Published On:1 Aug 2015
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