Fri, Mar 31, 2017
Shiv Mahalingham, a managing director in Duff & Phelps European transfer pricing practice, provides insight on Australia adopting simplified transfer pricing documentation. In addition to simplified reporting requirements, the guidance introduces a number of safe-harbors for intra-group transactions.
The Australian Taxation Office ("ATO") have acknowledged in recent guidance (Practical Compliance Guidance PCG 2017/2) that existing transfer pricing requirements "may impose an administrative burden disproportionate to your risk of not complying with the transfer pricing rules." The revised guidance provides a reduced documentation requirement for certain situations that include:
Distributors
Intra-group services
Low level inbound loans
Materiality
Management and administration services
Technical services
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