The Assistant Treasurer has released an exposure draft of the proposed amendments to implement the first stage of the transfer pricing reforms. The exposure draft provisions are accompanied by a draft explanatory memorandum to explain the proposed amendments.
These reforms were announced on 1 November 2011. The proposed amendments now released are designed to ensure that the transfer pricing articles contained in Australia's tax treaties are able to be applied and operate independently of Australia's unilateral transfer pricing rules in relation to treaty cases through explicit incorporation into the Income Tax Assessment Act 1997.