On 11 February 2016, the Australian Treasury launched a public consultation on the implementation of the transfer pricing guidelines developed as part of Actions 8-10 of the OECD BEPS Project, which focus on aligning transfer pricing outcomes with value creation. The new guidelines focus on:
- Transfer pricing issues relating to transactions involving intangibles (Action 8);
- Contractual allocation of risks and the resulting allocation of profits to those risks, as well as the level of return o…