Practical safe harbours and Australia's transfer pricing rules
Source: Taxation In Australia Journal Article
Published Date: 1 May 2019
In the context of complex intra-group dealings, the ATO is placing increasing reliance on the use of practical compliance guidelines (PCGs) to inform the market as to their view of transfer pricing risk for specific categories of international dealings. These PCGs can therefore assist Australian taxpayers in understanding transfer pricing issues of concern to the ATO and how to focus economic analyses demonstrating compliance with the transfer pricing provisions. Of critical importance, though, is the way PCGs are used by the ATO. Their legal status does not go beyond that of a statement of the ATO's view of risk, so it is important the transfer pricing risk indicators, being the key element of the PCGs, are not linked to arm's length outcomes.
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Details
- Published By: Michael Jenkins CTA
- Published On:1 May 2019
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