Evidence in the Australian Transfer Pricing Realm: The Price of Proof
New
Journal
Country
Australia
Published Date
Issue
International Transfer Pricing Journal 2026 (Volume 33), No. 5
Document
This article examines the growing importance of evidence in defending transfer pricing positions in Australia, where the Australian Taxation Office increasingly relies on data analytics, formal information gathering powers and a “show, not tell” approach to compliance. It outlines how taxpayers can identify, structure and maintain contemporaneous evidence across the transfer pricing life cycle to support their positions in reviews, audits and potential litigation.