The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, also known as the Multilateral Instrument (MLI), is a multilateral treaty that enables jurisdictions to swiftly modify the operation of their tax treaties to implement measures designed to better address multinational tax avoidance and more effectively resolve tax disputes.

These measures were developed as part of the OECD/G20 Base Erosion and Profit Shifting (BEPS) project.

More information on when the MLI can be found on the ATO website under “Multilateral Instrument”.


Documenting your transfer pricing to meet all of the requirements of Subdivision 284-E of Schedule 1 to the Taxation Administration Act 1953 may impose an administrative burden disproportionate to your risk of not complying with the transfer pricing rules. Simplified transfer pricing recordkeeping options have been developed to minimise the record-keeping for eligible taxpayers.

The updated Guideline in Practical Compliance Guideline PCG 2017/2 contains options that reflect the types of transactions or activities the ATO believes are low risk in the context of international related-party dealings.

This Guideline specifies the criteria for you to selfassess your eligibility to use one or more of the seven simplified transfer pricing record-keeping options:

  1.  small taxpayers
  2.  distributors
  3.  low value adding intra-group services
  4.  low-level inbound loans
  5.  materiality
  6.  technical services
  7.  low-level outbound loans.

Date of effect:The simplified transfer pricing record-keeping options contained in this version of the Guideline are available for taxpayers to apply to income years commencing on or after 1 July 2018 (or substituted accounting period).