Wednesday, 6 June 2012
Analysis of bill containing proposed retrospective transfer pricing law changes
As indicated previously, the proposed "treaty-equivalent" transfer pricing rules announced by the Australian Government in November 2011 and released in draft in March 2012 are now before Parliament. The Bill and Explanatory Memorandum (EM) that were introduced into Parliament have both been significantly reworded from the drafts released in March. The result is much better drafting which has clarified some areas of uncertainty. There are other areas that remain uncertain or contentious, but given that the Bill has now entered Parliament it is unlikely that further substantial changes will be made before enactment, which could be by the end of June 2012.
PwC provides a brief executive summary and a more detailed analysis of key features of the proposed changes in this document.