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These services often include management, administrative, technical and support activities delivered across a group resulting in closer ATO scrutiny and a clear expectation that services are necessary, deliver value, and are priced at arm’s length.
Each service must pass a clear benefit test showing why the service is needed, what it involves, and how the recipient benefits. Services that do not meet this test risk being denied or adjusted by the ATO. Clear explanations and concurrent documentation help protect your position.
Most related party services use cost‑based pricing, often through a cost‑plus approach. Costs must be identified, allocated methodically and supported by an appropriate mark‑up which translates to less reliance on judgement and more reliance on evidence, including economic analysis or comparable data.
Some services are routine and do not drive significant value. For these low‑value services, the ATO may accept simplified pricing and documentation where conditions are met. This reduces compliance effort while keeping higher‑risk services well supported.
Managing related party services is often complex, and our support can help your business move from compliance driven processes to confident, well‑reasoned positions. We offer the following services:
A conversation with Grant Thornton can help you challenge existing arrangements, manage risk, and build transfer pricing positions that stand up over time.
The ATO’s draft PCG 2026/D1 introduces a new compliance framework for attributing risk weighted assets to Australian branches of foreign banks, reshaping thin capitalisation methodologies and documentation expectations.
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US tariffs and IEEPA changes impacts on Australian exporters and trade compliance.
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