Income Tax: Cross Border Profit Allocation - Review of Transfer Pricing Rules

This consultation process has now been completed. Submissions available
Consultation Type
Consultation Paper

Key Documents

The Government announced on 1 November 2011 that it would introduce changes to the existing transfer pricing rules, to bring them in line with Australian and international developments in the area.

This Consultation Paper outlines the history of the transfer pricing rules, as well as a number of suggested areas for change. These include the introduction of an arm's length standard that reflects the international norms, interpretation of new rules in a manner that best secures consistency with OECD guidance and application of the new rules on a self-assessment basis.

The Consultation Paper further discusses other related issues including methodologies for determining an arm's length outcome (as well as criteria for their selection), comparability standards, and documentation and penalty provisions.


28 submissions were received for this consultation, including 3 confidential submissions.

BDO - pdf 192.71 KB
Burnett, Chloe - pdf 152.78 KB
Chevron - pdf 377.91 KB
CPA Australia - pdf 62.86 KB
Crowe Horwath - pdf 54.75 KB
Ernst & Young - pdf 1.97 MB
Law Council of Australia - pdf 372.61 KB
Moore Stephens - pdf 246.98 KB
Pitcher Partners - pdf 436.1 KB
PWC (1) - pdf 451.74 KB
PWC (2) - pdf 308.99 KB
RSM Bird Cameron - pdf 135.85 KB
The Tax Institute - pdf 174.17 KB
Uniting Church - pdf 55.69 KB