Multinational establishments often utilize transfer pricing to allot revenue among subsidiary and affiliate firms that are part of the central organization. The procedure has several regulations placed on it to ensure that taxes are imposed on gains where value is created. A global attempt to constrict the restrictions and increase the documentation conditions for this practice is underway, adding extra work and obligation to the duties of the corporate tax specialist. Here are the documentations required for transfer pricing.
What is transfer pricing documentation?
Transfer pricing documentation shows the firm’s related party transactions align with the arm’s length principle. A viable transfer pricing documentation in Australia must show how affiliated parties share the functions, assets and risks. It should be done in each related party transaction so that people can know whether or not they are familiar with the firm.
Transfer pricing documentation requirements include:
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International dealing schedule (IDS )
Firms with aggregated related party dealings higher than AU$2 million should complete (IDS) when submitting Australian income tax returns. The schedule reveals the types and amounts of the related party dealings in a given financial year. Additionally, it illustrates the applied transfer pricing technique and the level of transfer pricing documentation prepared for the transaction.
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Transfer pricing manual
Entities in Australia that are part of international groups must keep comprehensive documents of their transfer pricing in Australia. They are known as ‘Transfer Pricing Manuals’. They assist the ATO in understanding the firm’s tax status and ensure that profits are documented correctly. An Australian Transfer pricing should comprise the following:
- An overview of the group’s organizational structure
- Global and Australian business activities
- Research of the relevant sectors in which the group operates internationally and in Australia.
- The Transfer Pricing Manual needs to be in place before the entity submits its income tax return.
Several small Australian firms may opt for simplified transfer pricing record-keeping options to suit their business. It highly relies on the business model and the related party transactions in a financial year.
Additional transfer pricing documentation for significant global entities
Australia has embraced Country by Country (CbC) reporting as an extra measure to manage international tax management. It helps in preventing multinationals from directing their gains to low-tax jurisdictions. However, this only applies to significant global entities(SGEs) which fall under multinational groups with worldwide revenue of AU$1 billion or more. The SGEs must submit the reports in Australia within 12 months of the entity’s financial year-end per the requirements.
As a multinational business with an Australian entity, you must review transfer pricing and documentation. It’s done continuingly, and expert help is recommended.
Multinational business with an Australian entity requires reviewing the transfer pricing reporting and documentation requirements. It’s to be done continuously, and expertise assistance is recommended. The company is always in the best position to offer a correct picture of its business operations. So it’s crucial to ensure the business meets all the requirements to the letter to prepare a viable transfer pricing documentation.
