This Draft, released on Wed 16.4.2014, explains a process for transfer pricing documentation when ATO officers conduct a review of transfer pricing.
The ATO says the transfer pricing documentation requirements of an entity as outlined in s 284-255 of the TAA will be met where the entity has made its best efforts to comply with those requirements, having regard to the materiality of the matter to the entity’s overall Australian tax position.
The Draft Practice Statement outlines what it says is a practical process for transfer pricing documentation to be followed by tax officers when undertaking a review of transfer pricing. To ensure consistency, the ATO outlines a 5-step process to be followed by tax officers.
COMMENTS are due by 30 May 2014. ATO contact – Andrew Phlorides – Tel: (03) 9285 1180; Fax: (03) 9285 1410; Email: andrew.phlorides@ato.gov.au.
[LTN 73, 16/4/14]