The Australian Taxation Office (ATO) has published guidance on the “international related-party agreements” to be furnished in Part B of the Australian Local file for controlled transactions disclosed in Part A. The publication follows an initial round of consultation in late 2016.
Among the provisions in the guidance are the following items.
Taxpayers need to consider performing an agreement “stock-take” and review their position and approach to be taken on agreements that may require liaison with the legal team and head-office functions. The agreement guidance also influences the grouping of transactions for Part A and, therefore, must be considered when completing Part A of the Australian Local file. Tax professionals expect the release of further guidance for Part A in the near future.
For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services practice in Australia:
Jane Rolfe | +61 3 9288 6341 | firstname.lastname@example.org
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