The Resource Australian reforms

Australian reforms

Australian reforms
Australian reforms
This article looks at the recently released Tax Law Amendment (cross border transfer pricing) Bill 2013: modernisation of transfer pricing rules, exposure draft legislation on the second stage of the transfer pricing legislative reform. The main features of the exposure draft are: (1) the arm's length principle will be interpreted not by reference to an arm's length price, but instead by reference to an entity's "economic contribution" to Australia; (2) self-assessment will be introduced for transfer pricing, aligning these provisions with the rest of Australia's tax law, (3) an eight year amendment period will be introduced for transfer pricing adjustments, removing the current indefinite period and (4) guidelines for preparation of documentation have been introduced, with those entities choosing not to prepare documentation losing their ability to advance the "reasonably arguable position" defence in the event of penalties. The application of the new rules to trusts and partnerships are the subject of special rules
Citation source
In: Transfer pricing international journal. - London. - Vol. 13 (2012),
  • Hayley, A
  • Holt, B
Language note
  • transfer pricing
  • arm's length principle
  • PE
  • self-assessment
  • documentation requirements
  • penalties
  • royalties
  • transfer pricing adjustment
Australian reforms

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