miércoles, 8 de marzo de 2017

Australia: Final guidance released on assessing the transfer pricing risk of hubs and centralized operating models

The Australian Tax Office (ATO) has released its Practical Compliance Guideline (PCG 2017/1) “ATO compliance approach to TP issues related to centralised operating models involving procurement, marketing, sales and distribution functions” (the Guidance). This finalizes the guidance issued in a draft discussion paper in August 2016.

The Guidance, applicable to all new and existing hubs from January 1, 2017, provides a framework to self-assess the transfer pricing risk of centralized operating models or ‘hubs’. The guidance has evolved following a number of significant audits the ATO has conducted in this area and is intended to set clear boundaries around a ‘low risk’ zone that taxpayers are encouraged to operate in. Taxpayers within the low risk zone should not be subject to ATO scrutiny, while taxpayers outside this zone can expect the ATO to closely examine the transfer pricing arrangements of their hub. Taxpayers outside the low risk zone should ensure they maintain documentation in accordance with the Guidance at an audit-ready standard.

Source & more info: PwC,  ATO

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