Tim Keeling’s Post

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Partner in Charge, Global Transfer Pricing Services at KPMG Australia

Good summary by Sophie and Sam of some of the new tweaks to the TP rules, and their potential flow on impacts

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Partner, Global Transfer Pricing Services - KPMG

The Australian Government is proposing to retrospectively update the guidance materials relating to Australia’s transfer pricing laws to the 2022 version of the OECD Transfer Pricing Guidelines. These updates include: - updated guidance on the Transactional Profit Split Method; - new guidance on Financial Transactions; and - new guidance for tax administrations on the application of the approach to hard-to-value intangibles. Taxpayers with intra-group financing arrangements, intangible arrangements, or arrangements where Australia is a party to ‘unique and valuable’ contributions, highly integrated activities and/or shares in the assumption of economically significant risks, should review their transfer pricing policies and documentation given a likely increased focus from the ATO on these types of arrangements.

KPMG Tax Now: Australia to adopt updated OECD transfer pricing guidance

KPMG Tax Now: Australia to adopt updated OECD transfer pricing guidance

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