Australia has elevated its attack on global transfer pricing,
however challenges and difficulties remain in the practical
application of the proposed new transfer pricing laws.
OVERVIEW AND BACKGROUND
In late 2012, the Australian Government released exposure draft
legislation dealing with the second instalment of Australia's
updated/revised Transfer Pricing Rules (TP Rules). The proposed
second instalment of our TP Rules is contained in draft Subdivision
815-B to Subdivision 815-E of the Income Tax Assessment Act
1997(Cth) (ITAA 97).
The second instalment of our TP Rules is intended to complement
and update the amendments contained in Subdivision 815-A of the
ITAA 97, which passed into law in September 2012. While Subdivision
815-A dealt with assessing powers under the equivalent of our
Double Tax Treaties, the second instalment of our TP Rules deals
more broadly with both treaty and non-treaty countries.
