Australia is increasingly giving attention to transfer pricing issues and has recently introduced changes in the law to align the transfer pricing rules more closely to the OECD Guidelines.

Taxpayers need to be completely ready for an Australian Taxation Office (ATO) review; particularly if they have been parties to complex transactions, merger and acquisition activity, or other similar transactions. In the event that a transfer pricing review happens the taxpayer needs to guarantee that the documentation in connection to pricing is sufficient to safeguard the position taken in the tax return.