Australia: Retrospective transfer pricing law passed by Parliament

Tax Controversy & Dispute Resolution ()

The Australian Parliament has today passed the new “treaty-equivalent” transfer pricing rules. The new rules will apply retrospectively from 1 July 2004. The rules provide the Commissioner with an additional power to make transfer pricing adjustments to dealings between Australian taxpayers and related parties in countries with which Australia has executed a Double Tax Agreement. See our PKN alert of June 5, 2012 for an overview of the new rules.