ATO Publishes Simplified TP Record Keeping Options

On February 22, the Australian Taxation Office (ATO) released Practical Compliance Guideline outlining simplified transfer pricing record-keeping options intended to minimize the record-keeping for eligible taxpayers.

Purpose of the Guidelines

By releasing the new guidance, ATO aims to reduce the record-keeping requirements and to assist taxpayers in complying with relevant tax laws. As a result, the guidelines aim to decrease the compliance costs and compliance burden for multinationals. Offering an administrative safe harbor also allows ATO to better manage risks associated with international related party dealings by directing resources to transactions and activities that we deem to be higher risk.


The options contained in the guideline reflect the types of transactions or activities ATO believes are low risk in the context of international related party dealings. The guideline specifies the criteria for multinationals to self-assess their eligibility to use one or more of the eight simplification options.

There are eight simplified transfer pricing record keeping options available:

  • small taxpayers,
  • intra-group services,
  • low-level inbound loans,
  • management and administration services,
  • technical services, and
  • low-level outbound loans.

The guidelines are published in the Practical Compliance Guideline (PCG) online guide. 

Source: ATO

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