Australia updates guideline on simplified transfer pricing record-keeping options

The Australian Taxation Office on November 11 amended its practical compliance guideline on simplified transfer pricing record-keeping options to provide maximum and minimum interest rates for low-level inbound and outbound loans for 2022.

The guideline also includes updated examples with respect to meeting the low-level inbound loan and low-level outbound loan eligibility criteria.

The guideline, in general, describes eligibility for simplified transfer pricing record-keeping options, reflecting types of transactions or activities that the Australian Taxation Office believes to be low risk in relation to international related party dealings. It sets out criteria for taxpayers to self-assess their eligibility to use one or more of seven available simplified transfer pricing record-keeping options.

One such simplification option relates to low-level inbound loans, another to low-level outbound loans.

For low-level inbound loans, interest rates must be no more than 1.83% in the 2022 income year. This is an increase from the 1.79% maximum rate in effect for 2021. Additional eligibility requirements apply.

For low-level outbound loans, the interest rate must be no less than 1.83% (the same increase from 2021). Additional eligibility requirements apply.

 

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