Transfer Pricing – Practical guidance for your group on the implementation of the new BEPS changes: presented by BDO and the Australian Taxation Office.
16 November 2016
Institute of Chartered Accountants
2 Mill St,
2016 has seen some of the biggest transfer pricing changes for WA businesses. There has been a progressive tightening of our transfer pricing legislation over successive Federal Budget alongside specific ATO initiatives targeting perceived avoidance in our market. At the same time, WA businesses are dealing with the implications of BEPS Actions 8 - 10 on value creation (applying to all multinationals) and Action 13 relation to transparency - requiring new documentation and disclosures (for businesses with a global turnover of more than $1 billion AUD.)
Join BDO and the Australian Taxation Office in conjunction with Chartered Accountants Australia New Zealand in Perth for a seminar to provide you with:
An update from the Australian Taxation Office of some of the key transfer pricing changes impacting WA business including:
- BEPS disclosure requirements (master file, country file and Cbc reports)
- Discussion paper on marketing hubs
- Potential changes to quasi equity rules
- Diverted Profits Tax
- Taxpayer alert on crossborder leasing arrangements
- Latest ATO approach to TP audits and the APA program
The key focus of the ATO and the OECD is an economic substance and the commerciality of arrangements. In order to be able to address these changes from a practical perspective, Nick Drizen, Transfer Pricing lead for WA with Kathy Sanchez, Senior Manager, will provide practical guidance on getting your group BEPS ready regardless of size. This will include:
For groups with a turnover of greater than $1 billion AUD:
- Details of BDO Pan Asia survey of readiness of similar groups to implement BEPS. How do you rank against your peers ?
- What is a BEPS dry run and the potential benefits?
- How to use ratio analysis to identify potential risk areas?
- Adjusting your TP strategy to take account of BEPS rules in different jurisdictions.
For all groups, devising a global documentation strategy:
- What impact will BEPS have on your current TP structures?
- How to adjust documentation for high/low risk countries?
- How to produce substance based transfer pricing documentation in accordance with Actions 8 - 10 to mitigate your potential audit risks?
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