Australia intensifies attack on Global Transfer Pricing:
New Transfer Pricing Legislation introduced along with expanded
General Anti-Avoidance Provisions
OVERVIEW AND BACKGROUND
On Wednesday 13 February 2013, the Australian Government
introduced into Parliament a new package of integrity measures
including modernised and expanded Transfer Pricing Rules (TP Rules)
and revised General Anti-avoidance Rules - the latter is known as
Part IVA. These integrity measures are contained in Taxation Laws
Amendment (Countering Tax Avoidance and Multinational Profit
Shifting) Bill 2013.
The TP Rules provide a new and comprehensive transfer pricing
regime and are principally outlined in the new Subdivision 815-B, C
and D of the Income Tax Assessment Act 1997 (Cth) (ITAA
97). These TP Rules will complement and ultimately supplant the
treaty equivalent transfer pricing assessing powers contained in
Subdivision 815-A, which passed into law in September 2012.
