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Transfer pricing - "if the CUP fits..."

Publication date: 27 Sep 10 | Source: CCH TAX WEEK

Issue: Issue 37 September 2010

Pages: pp. 1-4

Abstract:
This article focuses on the manner in which the taxpayer in the SNF case satisfied the burden of proof to show that the Commissioner's assessments were excessive.

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Author profile

Ian Kellock CTA
Photo of author, Ian KELLOCK Ian Kellock, CTA, is a Tax Partner at Ashurst and has extensive experience in Australian corporate and international tax, advising Australian and foreignowned banking and financial services groups. Ian’s practice primarily focuses on due diligence and structuring for mergers, acquisitions and divestments, financing transactions and group reorganisations. Ian has significant recent experience advising on all income tax aspects of financing and refinancing transactions and asset and debt reconstruction projects. - Current at 02 November 2018
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