Australia BEPS Action 13 Summary:

Re-Examine Transfer Pricing Documentation

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Australia has joined the OECD Inclusive Framework for the global implementation of the BEPS project. As an OECD member, Australia has committed to implementing the four BEPS project minimum standards — i.e., Actions 5 (exchange of tax ruling information only), 6 (preventing treaty abuse), 13 (country-by-country (CbC) reporting only), and 14 (mutual agreement procedure only).Significant global entities (SGEs) are required to provide three statements to the Tax Commissioner: CbC report, master file, and local file containing information that will assist the Commissioner in assessing transfer pricing risk. All entities must continue to maintain specific transfer pricing documents to have a reasonably arguable transfer pricing position.

This report has in-depth information about these developments, including:
  • Q&A guidance on the new transfer pricing documentation requirements in Australia
  • Reporting requirements
  • Automatic exchange of CbC report information
  • Simplified record keeping
  • OECD transfer pricing guidelines
  • Guidance for tax administrations
  • Helpful links to news, analysis, and primary source materials

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