Transfer Pricing Consultation Paper
19 December 2011
On Tuesday 1 November 2011 when the foreigners were taking over the Melbourne Cup, the Assistant Treasurer put out a Press Release and Consultation Paper which deals with a number of well known issues in the transfer pricing area but has a surprise for foreigners – a retrospective amendment to the law to support the Australian Taxation Office view that tax treaties provide a separate power to make transfer adjustments.
This Tax Brief discusses what the proposed retrospective amendment may mean and comments on the issues canvassed in the Consultation Paper.
For our full Tax Brief click here