Australian Tax Treaties
Where a resident of a Contracting State considers the actions of the other Contracting State results or will result in a transfer pricing adjustment not in accordance with the arm ' s length principle, the resident may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the first-mentioned State. The case must be presented within three years of the first notification of the adjustment.
2
The competent authorities shall endeavour to resolve any difficulties or doubts arising as to the application of the arm ' s length principle by a Contracting State regarding transfer pricing adjustments. They may also communicate with each other directly for the purposes of this Article.
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