Australia Increasingly Disputing Transfer Pricing in Audits

Sept. 26, 2025, 10:39 AM UTC

Global profit shifting by public and multinational companies continues to be a source of major tax disputes for Australia’s tax office, it reported Friday.

About 70% of the Australian Tax Office’s current income tax audits are related to international related party dealings and cross border investments and structures, the office said in a findings report.

“Transfer pricing is the most relevant event attracting our attention, where well understood issues of financing and marketing hub arrangements continue to be in focus,” ATO said.

Seven of 18 legal disputes settled in 2024-25 involved transfer pricing risks, the ATO said.

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