Shiv Mahalingham Published in Bloomberg BNAs Tax Planning International Asia Pacific Focus

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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:

  1. Small taxpayers
  2. Distributors

  3. Intra-group services

  4. Low level inbound loans

  5. Materiality

  6. Management and administration services

  7. Technical services

  8. Low level outbound loans


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