Transfer Pricing Agreement Australia

Australia bases its transfer pricing rules with other OECD countries on the “arm length principle.” This principle requires that the prices of goods and services sold to related international parties reflect what the independent parties would pay for the same good or service. Our transfer pricing specialists also have direct experience with ATO Transfer Pricing Reviews and advancing Pricing Agreements (APAs) with successful results. We can help you meet your transfer pricing obligations and ensure that you are in a secure position to refute any claims in the event of a ATO transfer price review. At the global level, the Organisation for Economic Co-operation and Development (OECD) has rapidly introduced new transfer pricing regimes, particularly with regard to intellectual property as part of its Basic Erosion and Profit Transfer (BEPS) initiative. This will have a significant impact on current and future transfer pricing structures for all sizes of the business. If you have international transactions with a related party – z.B a loan from your foreign subsidiary – your Australian tax may be affected if the transaction amounts do not comply with the principle of weapons length, in accordance with transfer pricing rules. Grant Thornton`s team will assist you with all local and international transfer pricing requests. For example, we have helped clients perform tasks, including: In addition, our transfer pricing approach can help identify more cost-effective agreements for your international transactions and use real business drivers for pricing decisions. Accru Felsers, accrued in Sydney, has been providing transfer pricing services for more than 20 years. Our transfer pricing books provide a reason why a particular comparison method has been used and why a company`s pricing meets the arm length requirement, as well as providing the information needed to meet the ATO. More and more countries around the world are recognizing the importance of transfer pricing and adopting transfer pricing laws. Meeting different requirements in many jurisdictions can be a complex and tedious task.

BDO Australia`s Transfer Pricing Practice helps groups navigate this rapidly changing transfer pricing environment. With the support of committed transfer pricing experts around the BDO network, we offer a number of planning, compliance, audit defense and benchmarking services. We can work with you to develop transfer pricing policies that are reasonable, flexible and consistent with your general tax planning strategies. Companies with international transactions with related parties can have us check or verify their transfer prices, with the possibility of price adjustments and penalties. If a subject does not meet Australian documentation obligations, an administrative sanction may be imposed. Under Australia`s transfer pricing rules, penalties are as follows: the principles of oecd transfer pricing guidelines are accepted in Australia and if national rules differ from the OECD guideline, it is mentioned. The ATO will examine the application of all transfer pricing methods recognized by the OECD and will also consider broader (or other) methods for certain facts and circumstances. The new transfer pricing rules do follow the OECD guidelines in Australia`s national transfer pricing rules. Preparation and review of transfer pricing documentation Transfer pricing rules in Australia require that the most appropriate method be used. In Australia, a new transfer pricing self-assessment regime is weighing more heavily on public servants to sign the income tax return to confirm that prices are poor for nearby parties and are supported by good quality documentation for transfer pricing.

In the absence of adequate documentation on transfer pricing, this may result in an increase in tax fines if reviewed by the Tax Office in Australia.