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Transfer pricing in practice for smaller enterprises
Published on 01 Jun 17 by "THE TAX SPECIALIST" JOURNAL ARTICLE
Unlike larger enterprises which have the budget and the people in-house to devote to complex transfer pricing issues, small-to-medium enterprises (SMEs) may not. Small-to-medium enterprises are faced with the dual challenge of understanding new technical issues and paying, in terms of time and dollars, to implement new compliance processes.
This article provides a summary of Australia’s transfer pricing and related documentation rules as they apply to SMEs. The author analyses in detail how the international dealings schedule and local transfer pricing documentation supporting the tax return lodged need to tell the same story; how penalty reduction is now linked to recommended transfer pricing documentation that presents a “reasonably arguable position”; how new ATO administrative practices under simplified record-keeping concessions reduce the size and cost of transfer pricing documentation; how self-assessment puts the onus on the taxpayer to lodge a correct tax return and the new country-by-country regime and separate lodgment processes that may cause smaller enterprises to be encompassed into yet more compliance burden.
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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