James Hardie: Tax Office Issues Transfer Pricing Position Paper

The Australian Taxation Office issued a transfer pricing position paper for the income years starting April 1, 2010 through March 31, 2019.

• If the company is ultimately unsuccessful in disputing the ATO’s position, the ATO calculated the amount of additional tax payable for the audit period to be approx. A$110 million, excluding any consequential adjustments, interest charges and/or penalties the ATO may impose
• Position paper sets out the ATO’s view that certain profits related to arrangements with the company’s technology holding company based in Ireland should be allocated to Australian subsidiaries of the company and taxed in Australia
• ATO invited ...