Taxation Rulings

2. Taxation Rulings

2.1 New Transfer Pricing Rulings
TR 2014/6 Income tax: transfer pricing – the application of section 815-130 of the Income Tax Assessment Act 1997

This ruling focuses on the relevance of the actual commercial or financial relations to the identification of the arm’s length conditions


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TR 2014/8 Income Tax: Transfer Pricing Documentation and Subdivision 284-E Download PDF
PS LA 2014/2 Administration of transfer pricing penalties for income years commencing on or after 29 June 2013 Download PDF
PS LA 2014/3 Simplifying transfer pricing record keeping Download PDF
PCG 2017/2 Simplified Transfer Pricing Record Keeping Options (update) Download PDF
PS LA 2014/4 Administration of the penalty imposed under subsection 284 75(3) of Schedule 1 to the Taxation Administration Act 1953 Download PDF
PS LA 2015/3 Approval process for the application of subsections 815-130(2) to 815-130(4) of the Income Tax Assessment Act 1997 (ITAA 1997) Download PDF
PCG 2017/1 ATO compliance approach to transfer pricing issues related to centralised operating models involving procurement, marketing, sales and distribution functions Download PDF
2.2. Country-by-Country Reporting Rulings
LCG 2015/3 Subdivision 815-E of the Income Tax Assessment Act 1997: Country-by-Country reporting
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Local File High Level Design Download PDF

Country-by-Country reporting: Exemption Guidelines

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2.3. Other Taxation Rulings
TR 92/11 Application of Division 13 to Loans
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TR 97/20 Methodologies Download PDF
TR 98/16 International transfer pricing - penalty tax guidelines Download PDF
TR 1999/1 Services Download PDF
TR 2000/16 Correlative Adjustments/MAPs Download PDF
TR 2000/16A Addendum to the Transfer pricing profit reallocation adjustments, relief from double taxation and the MAP Download PDF
TR 2004/1 Cost Contribution Arrangements Download PDF
TR 2006/2 Deductibility of service fees paid to associated service entities: Phillips arrangements Download PDF
TR 2010/7 Interaction of transfer pricing & thin capitalisation rules Download PDF
TR 2011/1 Business Restructuring Download PDF
MT 2008/2 Administrative penalty for taking a position that is not reasonably arguable Download PDF
TD 2008/20 Where a taxpayer has supplied or acquired property under an international agreement and that gives rise to a debt interest or an equity interest as defined for the purposes of Division 974 of the ITAA 1997 Download PDF