Transfer Pricing Services
It takes an expert to maximise cross-border opportunities and remain compliant with relevant tax laws. The best professionals provide an international perspective yet have local experience with a deep understanding of tax legislation. One area of International tax that confronts many multinational groups is transfer pricing.
Transfer pricing legislation allows tax administrations to adjust cross-border pricing so that it conforms with arm's length principles. In Australia, there is no time limit for the Commissioner of Taxation to make a transfer pricing adjustment. In Roche Products Pty Ltd v. the Federal Commissioner of Taxation 2008, the Commissioner undertook an audit of the 1993 to 2003 years of income and issued amended assessments in 2004 increasing the taxpayer's taxable income. The resulting tax liability which accumulated over many years was very substantial.
Click on this link for the full Global Transfer Pricing Services brochure.
To read articles on transfer pricing issues, click on this link: Transfer Pricing Insight
Australian TP facts at a glance
Taxing Authority
Australian Taxation Office
Legislation
Division 13 of the Income Tax Assessment Act 1936.
Acceptable Methods
CUP, Cost Plus Method, Resale Price Method, Profit Split method,
TNMM.
Time limit for ATO to amend assessment
No time limit.
Penalty rate
Generally 5% to 50% plus penalty interest.
Advance Pricing Agreement available? and term
Yes and generally for 3 -5 years forward.
Benchmarking Data
The ATO prefers Australian data.