| What is Transfer Pricing? New to Transfer Pricing, our FAQ’s will help |
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| 1. Australian Transfer Pricing Tax Legislation 1.1. Australia’s New Transfer Pricing Legislation Subdivision 815 B, C and D, Subdivision 284-E These provisions repealed Division 13 and apply for income years commencing 1 July 2013 |
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| Exposure draft – Subdivision 815 B, C and D, Subdivision 284-E | Download PDF |
| Subdivision 815-A The new transfer pricing legislation Subdiv 815-A was enacted in 2012 with retrospective operation back to 2004 for treaty cases |
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| 2. Taxation Rulings 2.1 New Transfer Pricing Rulings TR 2014/6 Income tax: transfer pricing – the application of section 815-130 of the Income Tax Assessment Act 1997 This ruling focuses on the relevance of the actual commercial or financial relations to the identification of the arm’s length conditions |
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| TR 2014/8 Income Tax: Transfer Pricing Documentation and Subdivision 284-E | Download PDF |
| PS LA 2014/2 Administration of transfer pricing penalties for income years commencing on or after 29 June 2013 | Download PDF |
| PS LA 2014/3 Simplifying transfer pricing record keeping | Download PDF |
| PCG 2017/2 Simplified Transfer Pricing Record Keeping Options (update) | Download PDF |
| PS LA 2014/4 Administration of the penalty imposed under subsection 284 75(3) of Schedule 1 to the Taxation Administration Act 1953 | Download PDF |
| PS LA 2015/3 Approval process for the application of subsections 815-130(2) to 815-130(4) of the Income Tax Assessment Act 1997 (ITAA 1997) | Download PDF |
| PCG 2017/1 ATO compliance approach to transfer pricing issues related to centralised operating models involving procurement, marketing, sales and distribution functions | Download PDF |
| 2.2. Country-by-Country Reporting Rulings LCG 2015/3 Subdivision 815-E of the Income Tax Assessment Act 1997: Country-by-Country reporting |
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| Local File High Level Design | Download PDF |
| Country-by-Country reporting: Exemption Guidelines | Download PDF |
| 2.3. Other Taxation Rulings TR 92/11 Application of Division 13 to Loans |
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| TR 97/20 Methodologies | Download PDF |
| TR 98/16 International transfer pricing - penalty tax guidelines | Download PDF |
| TR 1999/1 Services | Download PDF |
| TR 2000/16 Correlative Adjustments/MAPs | Download PDF |
| TR 2000/16A Addendum to the Transfer pricing profit reallocation adjustments, relief from double taxation and the MAP | Download PDF |
| TR 2004/1 Cost Contribution Arrangements | Download PDF |
| TR 2006/2 Deductibility of service fees paid to associated service entities: Phillips arrangements | Download PDF |
| TR 2010/7 Interaction of transfer pricing & thin capitalisation rules | Download PDF |
| TR 2011/1 Business Restructuring | Download PDF |
| MT 2008/2 Administrative penalty for taking a position that is not reasonably arguable | Download PDF |
| TD 2008/20 Where a taxpayer has supplied or acquired property under an international agreement and that gives rise to a debt interest or an equity interest as defined for the purposes of Division 974 of the ITAA 1997 | Download PDF |
| 3. Relevant Transfer Pricing Cases Roche Products Pty V. Commissioner of Taxation 22 July 2008 |
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| SNF (Australia) Pty Limited V. Commissioner of Taxation 25 June 2010 | Download PDF Download PDF |
| Chevron Australia Holdings Pty Ltd v Commissioner of Taxation (No 4) [2015] FCA 1092 (23 October 2015) |
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| Chevron Australia Holdings Pty Ltd v Commissioner of Taxation [2017] FCAFC 62 (21 April 2017) |
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| 4. ATO Transfer Pricing Publications |
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| Introduction to Concepts and Risk Assessment | Download PDF |
| Applying the Arm’s Length Principle | Download PDF |
| Marketing Intangibles | Download PDF |
| Advance Pricing Arrangements | Download PDF |
| Attributing Profits to a Dependent Agent Permanent Establishment | Download PDF |
