As published in The Age on 23rd November 2015, the ATO is quoted to take a tighter approach to deals with multinationals on future taxes, meaning agreeing up front in the form of an Advance Pricing Arrangements. The ATO is becoming more ‘picky’ about entering into agreements and has delayed some renewals with major multinationals. To read more of the Age article click here http://www.theage.com.au/business/the-economy/ato-takes-tighter-approach-to-deals-with-multinationals-on-future-taxes-20151028-gkkqq2
As we discussed in our newsletter back in July, the Australian Taxation Office (ATO) has released a new process for advance pricing arrangement (APA) negotiations (Practice Statement, PS LA 2015/4). The new process will apply to all ongoing APA negotiations and future APA requests (both new APAs and renewals). The APA program has been updated to ensure it reflects changes in global economy and the ATO’s anti-profit shifting work.
The new process includes three key steps as follows:
If your company is interested in entering into an APA with the ATO, you should carefully assess your resources and effort required, particularly during stage 1, taking into account that there is no guarantee the ATO will accept you into the APA program.
It will be critical to engage specialist consultants from the beginning of the process to manage the relationship with the ATO and to assist with the technical documentation.
Singapore is often a preferred location for setting up headquarters as the door to conduct business in Asia. The IRAS has released its views on how Singapore HQ's should plan and implement their transfer pricing framework. Want to know more? Read our article with our views on IRAS TP Guidelines for Singapore HQs.
The Malaysian Finance Bill 2020 incorporates transfer pricing-related changes to the current Income Tax Act, 1967 (“ITA”). The changes permit significantly greater authority to the Malaysia Inland Revenue Board (“MIRB”) and re-emphasises the importance of transfer pricing compliance, with effect from 1 January 2021.
Thec Covid-19 pandemic has triggered the most severe recession and is causing enormous damage to the world economy. The economic downturn will impact a group’s transfer prices, analysis and documentation, more so with the BEPS Action Plans in place and the high level of transfer pricing scrutiny across the globe.