Taxation Rulings

ResourcesTaxation Rulings

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

Download PDF
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
Download PDF
Local File High Level Design Download PDF

Country-by-Country reporting: Exemption Guidelines

Download PDF
2.3. Other Taxation Rulings
TR 92/11 Application of Division 13 to Loans
Download PDF
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