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The Australian Taxation Office (ATO) has updated its simplified transfer pricing record keeping guidance in Practical Compliance Guideline (PCG) 2017/2. The guidance is intended to provide relief from preparing full transfer pricing documentation for small taxpayers and/or low risk transfer pricing arrangements.

The revised guidance brings both good and bad news. Welcome changes include the removal or relaxing of certain technicalities which have precluded some taxpayers from relying on the measures previously. Less welcome changes include the tightening of the eligibility criteria for some of the options, and a significantly lower interest rate permitted under the low-level inbound loan option.


For further information, please speak to your usual PwC adviser.