The finalised ATO guidance enables taxpayers to self-assess their transfer pricing risk.
The Australian Taxation Office (ATO) released PCG 2020/1 Transfer pricing issues related to projects involving the use in Australian waters of non-resident owned mobile offshore drilling units – ATO compliance approach on 19 February 2020.
The finalised PCG is broadly in line with the draft version (PCG 2019/D5) released in September last year and primarily affects Australian taxpayers that lease a vessel (a “MODU”) from a non-resident related party under a bareboat charter arrangement for drilling and drilling-related activities (e.g. pipe-laying and heavy-lift vessels) in Australian waters.
The key amendments from the draft version of the PCG included:
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