Transfer Pricing: ATO's views on reconstruction provisions

ATO views on transfer pricing reconstruction provisions

The Australian Taxation Office (ATO) has issued its final views on how it will administer the new transfer pricing reconstruction provisions.


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The significance of these reconstruction provisions is that they authorise the Commissioner to re-price, reconstruct or disregard a cross-border transaction, should it not be considered arm’s length (either by reference to comparable third party evidence or hypothesising as to what independent third parties would do in comparable circumstances).

KPMG's Transfer Pricing Update provides you with a recap of the law, the ATO’s ruling, key observations and what action you should take.

Transfer Pricing Updates

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KPMG’s international Transfer Pricing Services team can help generate tax efficiencies and reduce the risk of challenges from revenue authorities.

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