Final guidance on the ATO’s controversial transfer pricing ‘reconstruction’ powers

Deloitte insights on the release of TR 2014/6 providing guidance on ATO’s transfer pricing ‘reconstruction’ provisions

Two days before G20 leaders gather in Brisbane to address multinationals’ tax avoidance, Taxation Ruling TR 2014/6 has been released, representing the Commissioner of Taxation’s guidance on the application of section 815-130 of the Income Tax Assessment Act 1997 (ITAA 1997). The ruling drives home Australia’s message that it is taking a tough stand against multinationals’ base erosion and profit shifting activities, and that the Australian Taxation Office (ATO) will use its strong and wide-ranging powers to challenge such activities. 

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