Build a transfer-pricing facts table under Division 815 of the ITAA 1997
Key facts
- Human involvement
- RedLawyer-led
- How AI is used
- Tabulate related-party transactions, prices, contracts and comparables against the arm's-length method the lawyer selected, and flag thin-capitalisation issues.
- What the lawyer must review
- Use the output as orientation only, not analysis
- Apply the 2024 thin-cap tests (fixed ratio, group ratio, third-party debt), not the safe harbour
- Check PCG 2025/2 and draft PCG 2025/D2 against the financing
- Use real financials and comparables
- Written for / version
- Commonwealth versionCth
Rules that apply
The document starts from the task name. Change it if this piece of work is different.
Who does what
| Role | What they do |
|---|---|
| Assistance | Supporting preparation only. Potential support includes identifying points for review. Confirm the tool’s capability and permitted scope. Substantive advice, judgement and any restricted content remain with the responsible human. |
| Lawyer | Perform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use. |
Checklist
- Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.