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Practical approach to preparing transfer pricing documentation paper

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Published on 16 Mar 07 by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA

This paper covers:

  • why prepare documentation? Risk mitigation and strategic planning
  • how to approach the process of writing it all down
    • build on and support schedule 25A related party disclosure
    • know the business and industry and know what data base will support the chosen method
    • use the available database knowledge to benchmark under the method selected and come to a conclusion
    • can overseas databases be used? What the ATO uses
  • what do you do if the result doesn’t support the outcome - is it arm’s length?

Author profile

Christopher Bowman
Chris is a Director at William Buck in Sydney and is primarily responsible for international tax advice. Chris joined the Taxation Consulting Group of William Buck in 2005 after over 15 years experience with PwC in Australasia and Europe and recently, 2 years in the ATO Transfer Pricing Practice. He was previously an Executive Level member of the Australian Taxation Office Transfer Pricing Practice, located in Large Business and International, Sydney, and a designated Competent Authority in the Asian team. - Current at 08 February 2007
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