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SME and private clients: Transfer pricing outside the top 1,000

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Published on 01 Oct 19 by "THE TAX SPECIALIST" JOURNAL ARTICLE

The ATO has focused significant resources and attention in recent years to managing transfer pricing risk through large corporate assurance programs and the release of risk guidance through practical compliance guidelines, tax determinations and tax alerts. In the authors’ view, this approach is aimed at managing the tax risk of large businesses. As large businesses provide a significant portion of tax in Australia, the ATO’s focus on gaining assurance that these entities are paying their fair share of tax is not unexpected. However, it seems that the ATO has ignored, or is unaware of, the unintentional consequences that this focus has had on managing transfer pricing risk in the small-to-medium enterprise (SME) business segment. This article identifies transfer pricing considerations and challenges currently faced by SMEs and outlines the ATO’s evolving approach to dealing with the transfer pricing arrangements of SMEs.

Author profiles

Aileen O'Carroll
Aileen O’Carroll is Partner/Executive Director in the Tax Consulting division of Pitcher Partners Melbourne and heads up the firm’s transfer pricing service offering. Aileen has over 16 years consulting experience providing advice on a broad range of transfer pricing matters to clients across a range of different industries both in the United Kingdom and Australia. Her career commenced in the UK corporate tax environment but quickly transitioned into transfer pricing in both the United Kingdom and Australia. Prior to joining Pitcher Partners in 2016, she developed her transfer pricing expertise working as an adviser for over a decade at a Big 4 firm, and at NAB leading its global Country by Country reporting project. - Current at 09 August 2023
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Christine Cornish
Click here to expand/collapse more articles by Christine Cornish.

 

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