On 10 August 2016, the Australian Taxation Office (ATO) published a discussion paper for public comment on a draft practical compliance guideline that sets out the ATO's compliance approach to transfer pricing issues related to offshore marketing hubs. In particular, the guideline is meant to assist taxpayers in:
- Assessing whether their hub arrangements pose a transfer pricing risk and how they can work with the ATO to mitigate risk;
- Understanding when the ATO may take a closer look at hub a…