---
title: "Build a transfer-pricing facts table under Division 815 of the ITAA 1997"
url: "https://ailawframework.com/practice/taxation/build-a-transfer-pricing-facts-and-methods-table/commonwealth"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-T1-R9-CTH"
practice_area: "Taxation"
tier: "red"
lawyer_review: "required"
jurisdictions: ["CTH"]
last_reviewed: "2026-09-23"
---

# Build a transfer-pricing facts table under Division 815 of the ITAA 1997

> Tabulate related-party transactions, prices, contracts and comparables against the arm's-length method the lawyer selected, and flag thin-capitalisation issues.

Canonical page: https://ailawframework.com/practice/taxation/build-a-transfer-pricing-facts-and-methods-table/commonwealth  
Last reviewed: 2026-09-23

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Taxation](https://ailawframework.com/practice/taxation.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| 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 | Commonwealth |
| Applies to | [Build a transfer-pricing facts and methods table](https://ailawframework.com/practice/taxation/build-a-transfer-pricing-facts-and-methods-table.md) |

## Checking plan

**Lawyer review required**

The responsible lawyer reviews the work against the instructions, sources and intended use.

- What the AI does: Potential support includes preparing preliminary structure or wording and summarising source material. Confirm the tool’s capability and permitted scope.
- What the lawyer does: Set the scope, verify the evidence, resolve exceptions and approve the final output for its intended use.
- Who reviews: Responsible lawyer with competence in the matter
- Basis: Suggested checking approach based on the task guidance. Complete the assessment for the actual tool, information and jurisdiction.
- Why: The plan reflects the described work and review requirements. Policy colours are not used to determine permission or checking.

## Checks the lawyer makes

1. Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
2. Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
3. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
4. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

## Notes

- Confirm the required checking with the responsible lawyer before work starts. The checking approach does not establish permission to use AI.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*