The Australian Taxation Office (ATO) on September 27 set out its approach to analyzing transfer pricing issues associated with the use in Australian waters of non-resident owned mobile offshore drilling units such as drill-ships, drilling rigs (including but not limited to submersibles, semi-submersible and jack-up rigs), pipe-laying vessels, and heavy-lift vessels.
The guidelines aim to help taxpayers assess the risk of their transfer pricing positions, revealing how the ATO analyzes transfer pricing outcomes in this area.
The guidance can be accessed at this link.
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