On 8 November 2018, the Australian Taxation Office (ATO) published a draft update to Practical Compliance Guideline (PCG) 2017/1, which covers the ATO's compliance approach to transfer pricing issues related to centralized operating models involving procurement, marketing, sales and distribution functions ("hubs"). The draft update includes the addition of a new Schedule 3 – Offshore Shipping Service Hubs.
Schedule 3 sets out the ATO's risk assessment framework, including the low risk bench…