Asia-Pacific Transfer Pricing Handbook

Contents

Preface

Part One: Country-By-Country Analysis

Chapter 1: Introduction

Part One: Country-by-Country Analysis

Part Two: Advanced Applications

Chapter 2: Australia’s Risk Assessment Transfer Pricing Approach

Introductory Issues

Transfer Pricing Reviews

Documentation Requirements

Preparation of the Documentation File

Applying the Arm’s Length Principle

Simplified Approach to Doing a Benchmarking Study

Four Steps for Testing International Transfer Prices

Decision Tree

How the ATO Scores Risk

Scoring the Three Levels

Score Graph

Outcome of Transfer Pricing Review or Audit

Audits Taking Place in Low-Risk Situations

Transfer Pricing Review Process

Categorizing the Results of the Transfer Pricing Review

How the Australian Transfer Pricing Audit Procedure Works

Australia’s Four-Step Process for Businesses

Chapter 3: Profit Attribution for a Dependent Agent’s Permanent Establishment in Australia

Permanent Establishment Concepts in Australia

Profit Attribution Concepts in Australia

The ATO’s Operational Approach

Determining Functional Analysis for a Permanent Establishment

Comparative Analysis for the Permanent Establishment

Application of the Resale Price Method

Application of the Cost Plus Method

Using a Transactional Net Margin Method

Using a Profit Split Method

Toll Manufacturers

Four Examples

Chapter 4: Australia’s Advance Pricing Arrangement Program

Pre-Formal APA Discussions

APA Processing Times

Unilateral and Bilateral APAs

The ATO’s APA Work in Process

APA Issues and Methods ...