Increasingly, Australian businesses are setting up operations offshore to reduce costs, especially in the Asian region. As businesses start to deal with related overseas parties, they are becoming subject to closer ATO attention due to the perceived risks to the Revenue. The ATO’s compliance activities for the SME market are now focusing on cross-border transactions, and in particular transfer pricing is being examined for smaller business. Recent developments mean now is the time for advisers to consider what kind of transactions are likely to attract ATO attention, and help their clients understand the implications and compliance requirements that follow.
This paper covers:
- the reform of Australia’s transfer pricing laws
- key focus areas in transfer pricing, eg business restructures, financing, IP and the internet/cloud
- permanent establishments
- transfer pricing documentation and tax return disclosures.