On March 16, 2012, the Australian Taxation Office (ATO) released an Exposure Draft of proposed retrospective amendments that will likely implement the country’s first stage of transfer pricing reform and reform Australia’s transfer pricing rules to bring them into line with the revised OECD Transfer Pricing Guidelines. The most significant provisions presented in the Exposure Draft confirm that Australia’s transfer pricing rules function differently than prior provisions that were set forth in the country’s various bilateral income tax treaties.
Significant tax risk to non-US companies created by America First Trade Policy
On his first day in office, President Trump signed two memoranda, the Global Tax Deal and the America First Trade Policy, covering noteworthy international...