This presentation focuses on an Overview of the ATO's RRIP initiative, problems with comparability of data, advance pricing arrangements, penalties, and future directions. It outlines : Recent important ATO Transfer Pricing Rulings; Increased emphasis and development of Schedule 25A questions; Available TPM's; Extent of written documentation; Risk of ATO audit; Document enforcement; Major RRIP experiences; Controversial transfer pricing activity; "Commercial realism"; ABS data; ABS versus ATO statistics; Advance Pricing Arrangements; Penalties; and Ralph Business Tax Reform Recommendations.
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