On March 16, 2012, the Australian Taxation Office (ATO) released an Exposure Draft of proposed retrospective amendments that will likely implement the country’s first stage of transfer pricing reform and reform Australia’s transfer pricing rules to bring them into line with the revised OECD Transfer Pricing Guidelines. The most significant provisions presented in the Exposure Draft confirm that Australia’s transfer pricing rules function differently than prior provisions that were set forth in the country’s various bilateral income tax treaties.
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One of the most common analyses in transfer pricing is on the cusp of being overhauled at a global level. This pending change has the potential to impact many...