Australian entities that meet certain requirements can shortcut
the usual lengthy and expensive transfer pricing record keeping
process.
The Australian Taxation Office's (ATO) transfer pricing
record keeping requirements are known for being quite onerous and
expensive. Companies typically need to call upon specialised
accountants to carry out a detailed study involving comparisons
with competitor arm's length pricing methodologies for
benchmarking purposes. However, in some circumstances Australian
entities are able to take a shortcut using simplified transfer
pricing record keeping (STPRK).
What is transfer pricing documentation?
Transfer pricing (TP) documentation needs to be prepared and
regularly updated by Australian entities which have international
related party dealings (IRPDs). They must demonstrate –
through detailed TP documentation – that the conditions of
the IRPDs are consistent with arm's length conditions so that
the taxpayer does not receive a
