A Transfer Pricing Solutions Provider in Australia
Planning & Litigation Support Solutions
We help design and implement Global TP Policy / review Agreements for Multinational Corporations. We also provide TP litigation support services.
Transfer Pricing Documentation Solutions
Transfer Pricing compliance requirements by delivering meticulously prepared Documentation as per Local TP Regulations and global standards.
TP Due Diligence / Health Check Services
We assist in identifying gaps by providing health check up from Legal, Corporate and TP documentation perspective.
We have access to various public financial and company databases, industry and directories which assist us to render comprehensive TP analysis.
Transfer Pricing in Australia
There are two “tiers” of Local File, with the amount of information required for a particular Local File tier reflecting the entity’s business operations, complexity and perceived level of risk:
– Short Form Local File: The reporting entity is only required to provide the Short Form Local File to the ATO if it meets at least one of the following criteria:
(1) the aggregate value of its IRPDs is less than AUD 2 million and it has no IRPDs on the short form exceptions list;
(2) it meets the Simplified Transfer Pricing Record Keeping (STPRK) criteria for “small taxpayers” and it has no IRPDs on the short form exceptions list;
(3) it meets the STPRK criteria for “materiality” and it has no IRPDs on the short form exceptions list.
– Local File: Where the reporting entity doesn’t meet the criteria for the Short Form Local File, it will be required to complete the Local File.
Legislation to implement the OECD’s CbC reporting requirements was passed in December 2015. Schedule 4 to the Tax Laws Amendment (Combating Multinational Tax Avoidance) Act 2015 implemented Australia’s CbC reporting regime, which is contained in Subdivision 815-E of the ITAA 97.
Australia’s CbC reporting rules apply to taxpayers in relation to income years starting on or after 1 January 2016. Under the CbC reporting rules, SGEs (multinational entities with an annual global income of AUD 1 billion or more) are required to provide the ATO with three statements within 12 months after the end of their income tax year.