Transfer pricing management, compliance and governance remain key issues for taxpayers in the Australian financial services sector. This session covers number of key themes that impact international related party dealings and transfer pricing policies for the sector, such as:
- Higher interest rates and increase in the cost of capital, and the subsequent impact on intra-group funding, internal reinsurance arrangements and other forms of risk transfer agreements
- The focus on outsourced services by tax and financial regulators
- Investment in technology and emerging issues related to the treatment of intangibles
- Governance and transparency, including developments in the area of CbC reporting.
Throughout the session, we discussed Identify and discuss the latest judicial and legislative developments, and highlight ATO areas of focus for Australian financial services entities. We will also outline the processes and potential outcomes of Mutual Agreement Procedures (MAPs), given the increased attention on transfer pricing and branch profit attribution, and consequently the risk of double taxation.