House of Representatives

Tax Laws Amendment (Cross-border Transfer Pricing) Bill (No. 1) 2012

Explanatory Memorandum

(Circulated by the authority of the Deputy Prime Minister and Treasurer, the Hon Wayne Swan MP)


The following abbreviations and acronyms are used throughout this explanatory memorandum.

Abbreviation Definition
ATO Australian Taxation Office
Commissioner Commissioner of Taxation
ITAA 1936 Income Tax Assessment Act 1936
ITAA 1953 International Tax Agreement Act 1953
ITAA 1997 Income Tax Assessment Act 1997
IT(TP) Act 1997 Income Tax (Transitional Provisions) Act 1997
MAP mutual agreement procedure article
OECD Organisation for Economic Co-operation and Development
OECD Guidelines OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
OECD Model OECD Model Tax Convention on Income and on Capital
SNF Commissioner of Taxation v SNF (Australia) Pty Ltd [2011] FCAFC 74
TAA 1953 Taxation Administration Act 1953

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