Consultation Paper - Income Tax: Cross Border Profit Allocation - Review of Transfer Pricing Rules

Date:

Content ID:

Abstract:

Treasury released a Consultation Paper on the changes to the transfer pricing rules as part of a consultation process to provide interested parties with an opportunity to comment.

The Government announced on 1 November 2011 that it would introduce changes to the existing transfer pricing rules, to bring them in line with Australian and international developments in the area.

This Consultation Paper outlines the history of the transfer pricing rules, as well as a number of suggested areas for change. These include the introduction of an arm’s length standard that reflects the international norms, interpretation of new rules in a manner that best secures consistency with OECD guidance and application of the new rules on a self-assessment basis.

The Consultation Paper further discusses other related issues including methodologies for determining an arm’s length outcome (as well as criteria for their selection), comparability standards, and documentation and penalty provisions.

Making a submission

Interested parties are invited to comment on the broad principles contained in this Consultation Paper. While submissions may be lodged electronically or by post, electronic lodgement is preferred. For accessibility reasons, please submit responses sent via email in a Word or RTF format. An additional PDF version may also be submitted.

All information (including name and address details) contained in submissions will be made available to the public on the Treasury website unless you indicate that you would like all or part of your submission to remain in confidence. Automatically generated confidentiality statements in emails do not suffice for this purpose. Respondents who would like part of their submission to remain in confidence should provide this information marked as such in a separate attachment. Legal requirements, such as those imposed by the Freedom of Information Act 1982, may affect the confidentiality of your submission.

It is expected that further feedback and comments will be requested during the legislative drafting process.

Closing date for submissions: Wednesday, 30 November 2011

Address written submissions to:

The Principal Adviser
International Tax and Treaties Division
The Treasury
Langton Crescent
PARKES ACT 2600

Email: transferpricing@treasury.gov.au

For enquiries, please call Neil Motteram on (02) 6263 2917.

Documents Available:

 Acrobat (PDF)

 Microsoft Word (RTF)

Related Items: