Two tranches of significant reforms have recently been made to the Australian transfer pricing rules. This presentation addresses a number of important issues through the eyes of a private practitioner, a large corporation,and a senior ATO officer, including:
- the government’s and taxpayers’ perspectives on this reform
- what stays the same?
- what are the changes?
- case study examples
- how does the Commissioner intend to apply his broad and significant powers?
- what are we seeing in practice from the ATO’s profit-shifting compliance focus?