A recent global transfer pricing round table discussion involving Alliott Group member firms from the EMEA, Americas and Asia Pacific regions reveals that transfer pricing rules vary significantly around the world. The implementation of the OECD BEPS Project recommendations targeting the avoidance of tax by international businesses is likely to be uneven and take time.
The round table report involving Alliott Group member firms including Hanrick Curran, provides a comparison of evolving transfer pricing legislation, trends and compliance requirements, and an update on how national tax authorities are responding to the OECD/G20 led Base Erosion & Profit Shifting (BEPS) project in countries such as the UK, Australia, USA, Belgium, Mexico, UAE, Netherlands, Brazil, Italy, Colombia and Spain. The report also provides useful information on what multinational corporations can do to avoid double taxation in these countries.
Australia and Asia Pacific
The Australia and Asia Pacific region was represented by Hanrick Curran’s Tax Partner Jamie Towers, who is also Alliott Group’s Asia Pacific Chairman. He indicates over the last five years, Australia has refreshed its laws to ensure it has some of the strictest transfer pricing rules in the world and consistency with OECD recommendations. The Australian Taxation Office (ATO) facilitates a proactive dialogue with business to provide certainty by entering into Advanced Pricing Agreements. The ATO has also been updating taxpayers on its views by publishing taxation rulings on its expectation of compliance requirements.
While Australia has already started implementing the BEPS recommendations, including country-by-country reporting, many other Asian countries, while generally accepting the OECD’s recommendations, are adopting different approaches and at different times.
Achieving the right advice and solutions that ensure success is no longer the sole preserve of large corporates and the wealthiest individuals. Through Hanrick Curran’s association with the Alliott Group, the essential ingredients for successful market entry, such as local knowledge and connections, technical expertise, sector experience, speed to market, flexibility and economies of scale, are now accessible to ambitious small and medium sized businesses. Founded in 1979, and with some 170 member firms in 70 countries, Alliott Group’s aim is to be the alternative, ‘go to’ resource for businesses and private individuals focused on cross border business.
Review a pdf of the 2016 Transfer Pricing Round Table report in full, or register on the Corporate Livewire website for an interactive version. For more information on international transfer pricing rules please speak with your usual Hanrick Curran adviser or alternatively contact Jamie Towers on 07 3218 3900.
Please note that this publication is intended to provide a general summary and should not be relied upon as a substitute for personal advice.