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Transfer pricing update - new APA guide and recent ATO rulings.

Publication date: 06 Apr 11 | Source: CCH TAX WEEK

Issue: Issue 11 March 2011

Pages: pp. 1-4


The ATO has released a practice statement on its advance pricing arrangement program, following on from other recent tax ruling guidance on the application of Australia's transfer pricing provisions to multinational enterprises.

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Author profiles

Claire Nicholson CTA
Claire Nicholson, CTA, is a barrister practising predominantly in taxation and commercial law. Claire’s tax expertise is in providing advice and appearing in matters relating to corporate transactions and structuring, including cross-border arrangements, financing, consolidation, anti-avoidance, Div 7A, corporate reconstruction (income tax, duty and GST), insolvency, trusts and SMSFs. Claire’s commercial experience includes class actions, contract, corporations, insolvency, insurance, property, trusts and equity, trade practices and competition. - Current at 31 October 2019
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Toby Knight CTA
Toby is a Tax Partner at Allens. He practises in corporate and international tax with particular expertise in dispute resolution, audits, transfer pricing, research and development, and tax litigation. He advises on mutual agreement procedures, tax treaty and structuring issues in transfer pricing matters and has over 17 years of experience in acting for many leading companies in a wide range of significant audits and tax litigation. These have included disputes in relation to capital gains tax, complex restructures and tax consolidation, Part IVA, foreign exchange transactions, franking credits and the application of different transfer pricing methodologies. - Current at 13 November 2013
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Julian Feiner
Julian works for Allens.
Current 1 September 2014
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