| 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 |
