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The role and design of a transfer pricing risk assessment framework for tax administrators

Published on 01 Oct 14 by "THE TAX SPECIALIST" JOURNAL ARTICLE

Transfer pricing has become one of the most important contemporary international tax issues. Transfer pricing risk assessment is a critical issue for all tax administrations to identify the right cases to audit and subsequently impose an appropriate level of transfer pricing enforcement in the event of non-compliance with relevant transfer pricing rules.

This article will provide an overview of transfer pricing issues and examine reasons why transfer pricing risk assessments play a significant role in tax administration. Based on the approach suggested by the Organisation for Economic and Co-operation and Development, a discussion of which factors should be considered when conducting transfer pricing risk assessment will be undertaken. A number of recommendations for designing procedures and methods for the assessment will also be made for developing countries drawing from the experience of developed countries where transfer pricing risk assessment procedures have already effectively been implemented.

Author profiles

Thu Ha Le Thi
Thu Ha Le Thi, Tax Inspector in Vietnam, Former Student of Master in Taxation, Curtin University.
Current 1 June 2016
Colleen Mortimer CTA
Colleen has been a lecturer at Curtin University since 1988. She currently teaches in a number of postgraduate tax units and has won many awards for her teaching. Prior to joining Curtin University she worked at the Australian Taxation Office and Arthur Andersen and operated her own business specialising in small businesses. Colleen is also a Senior Manager at BDO where she is responsible for the Learning and Development in both the Corporate and International tax area and the Business Services area. She also teaches for the Tax Institute in the CTA1 Foundations, CTA2A and CTA2B Advanced subjects, and CTA3 Advisory subjects. Colleen is also the CTA2B Advanced Subject Convenor - Current at 08 August 2018
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Prof Dale Pinto CTA-Life
Photo of author, Dale PINTO Dale is currently Professor of Taxation Law in the Curtin Law School as well as being the Chair of the Academic Board at Curtin University. Dale is the author and co-author of numerous books, refereed articles and national and international conference papers and sits on the editorial board of a number of peer-reviewed journals as well as being the Editor-in-Chief of several refereed journals. He is a member of the Board of CPA Australia and is also a Fellow of the Australian Academy of Law as well as being a Chartered Accountant, Chartered Tax Adviser and Honorary Life Member of the Tax Institute. He is also a Life Member of the Australasian Tax Teachers Association and the Australasian Law Teachers Association. Dale has been a registered tax agent for more than 25 years and was appointed by the Assistant Treasurer as one of the inaugural members of the National Tax Practitioners Board. He is a current member of the Board of Taxation’s Special Advisory Panel and the ATO’s Tax Technical Panel as well as the Chamber of Commerce and Industry’s Economic Development Forum in WA. Dale is a member of the Tertiary Education and Quality Standards Agency (TEQSA) Expert Panel in Accounting, Taxation and International Education. - Current at 13 August 2019
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