Australia: ATO releases PCG on simplified transfer pricing record-keeping

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On 22 February 2017 the Australian Taxation Office (ATO) released Practical Compliance Guideline (PCG) 2017/2 dealing with simplified transfer pricing (TP) record-keeping options and assisting taxpayers in complying with relevant tax laws.

The PCG outlines transaction types or activities identified as low risk for international related party dealings. The PCG also specifies the criteria for taxpayers to self-assess their eligibility to use one or more of the eight simplification options:

  • small taxpayers
  • distributors
  • intra-group services
  • low-level inbound loans
  • materiality
  • management and administration services
  • technical services
  • low-level outbound loans.

This PCG replaces the current information provided on the ATO website and provides the additional low-level outbound loans option.

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