Maintain transfer pricing documentation (Subdivision 815-D)
Multinational groups must keep contemporaneous transfer pricing documentation per Subdivision 815-D ITAA 1997.
Who must comply
Australian entities in multinational groups; threshold-dependent.
What triggers it
International dealings between associates.
When due
Contemporaneous — in place by tax return lodgement.
Evidence required
Master File, Local File, CbC Report; supporting analysis.
Max penalty
Documentation penalty up to $156,500 for failure to keep records; transfer pricing adjustment + interest + penalty tax
Summary
Subdivision 815-D of the ITAA 1997 sets contemporaneous transfer pricing documentation requirements. Aligned with OECD BEPS Action 13 — Master File, Local File and Country-by-Country Report depending on group size. Documentation must be in place when the tax return is lodged.
Enforced by
Source legislation
Topics
Source: https://ato.gov.au/businesses-and-organisations/international-tax-for-business/in-detail/transfer-pricing. Rules Mate is not a law firm. Always verify against the live regulator source before acting.