Australia Applying 2022 OECD Transfer Pricing Guidelines Retrospectively

The Australian Treasury recently concluded a brief consultation on Miscellaneous Amendments to Treasury Portfolio Laws 2024, which includes amendments that seek to ensure that the law operates as intended by:

• Correcting technical or drafting defects;
• Removing anomalies; and
• Addressing unintended outcomes.

One of the key amendments concerns the reference to the OECD Transfer Pricing Guidelines in Australia's transfer pricing law (Division 815 of the ITAA 1997), which is updated to refer to…