Australia

Transfer pricing (TP) outcomes of the base erosion and profit shifting (BEPS) project have been generally accepted as positive and embraced by the Australian government and Australia’s tax authority, the Australian Taxation Office (ATO). Reporting in the form of country-by-country reporting, consistent with OECD recommendations in Action 13 of the October 2015 OECD final BEPS report was implemented in December 2015 and, on 3 May 2016, the government announced its intention to amend Australia’s new TP rules to give effect to the TP recommendations in Actions 8–10 of the October 2015 OECD final BEPS report. The amendments were announced to apply from 1 July 2016. The domestic political environment is also having a significant impact on how BEPS is perceived in Australia, not least of all because of the Senate Economics References Committee inquiry into corporate tax avoidance. This inquiry was referred to the committee on 2 October 2014 and it was originally due to report in June 2015. Since then, the committee’s due date for reporting has been extended six times and it is now due to report by the end of September 2017. A number of multinational enterprises (MNEs) operating in Australia have appeared before the committee, particularly in the technology, energy and resources and pharmaceutical industries..