The new Australian transfer pricing laws have now been passed, nearly 18 months since first announced. The new rules will apply to income years beginning on or after 1 July 2013. The existing transfer pricing provisions will cease to have effect at the same time.
All multinationals with operations in Australia will be impacted by the new rules to some extent. Key practical issues for taxpayers to consider when the new rules come into effect include:
The ATO is planning to prepare new guidance addressing some of the practical issues arising from the new rules; however, this will require a significant amount of time and resources. We understand that priority will be given to preparing new guidance in respect of documentation and penalties.