Taxpayers may adopt positions that have low risk of noncompliance
Learning Centre • Taxpayers may adopt positions that have low risk of noncompliance
Learning Centre • Taxpayers may adopt positions that have low risk of noncompliance
As was discussed above, the Australian Taxation Office (ATO) has been very active in publishing practical compliance guidance on what
transfer pricing arrangements and outcomes represent regarding a low risk of noncompliance. If taxpayers can be managed to make these
concessions or if such arrangements can be justified, it is reasonable to expect that the ATO would regard the outcomes as presenting a low
risk of noncompliance.
These guides help organisations tackle a wide range of activities from returns and mark-ups for contract and distribution hubs to returns
for marketing and procurement hubs. Although these positions don't represent safe harbours , the ATO has stated that it will focus its
audit resources on arrangements that adopt one of these positions.
Additionally, the ATO recently published comments about the application of transfer pricing rules in relation to financial arrangements that
migrate away from LIBOR–based pricing. Additionally, the ATO recently published comments about the application of transfer pricing
rules in relation to financial arrangements that migrate away from LIBOR–based pricing.