On 3 December the federal government passed the Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015.
The Bill implements the recent guidance set by the OECD as part of its Base Erosion and Profit Shifting (BEPS) initiative with respect to Action Plan 13: Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting by introducing a new transfer pricing standard involving mainly:
The legislation will apply for years beginning on or after 1 January 2016. Further guidance from the ATO is expected on the application of this new transfer pricing standard.
Where the MAAL applies, the foreign entity will be taxed as if had made the sales through a deemed Australian permanent establishment. The MAAL will not operate, if under the current law or under the BEPS proposal, the foreign entity has a permanent establishment in Australia. Further guidance from ATO is contained in Law Companion Guideline (LCG) 2015/2.
For more information about these news measures and how can affect your company please contact Transfer Pricing Solutions on +61 3 5911 7001 or firstname.lastname@example.org www.transferpricingsolutions.com.au
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.