You have a non-Australian company selling products and/or services directly to the Australian market. To facilitate the sales, you have set up a subsidiary in Australia to provide various auxiliary services to your company.
The proceeds from the sales are retained by the non-Australian company which in turn pays the Australian subsidiary on a cost plus basis for the auxiliary services.
Sounds like you?
Lets talk TP and MAAL for Australia.
If you're an Australian company currently claiming tax deductions for cross-border payments then you MUST consider the imported mismatch
If your business is engaged in international dealings with related parties, and has more than $2 million of related-party dealings, you are required to complete an international dealings schedule (IDS) and lodge it with your income tax return for that year.
Multinational Anti-Avoidance Law (MAAL) is an anti-avoidance measure created to combat tax avoidance by multinationals using certain
transfer pricing arrangements or structures to avoid the attribution of profit to a permanent establishment in Australia.