Transfer pricing update - new APA guide and recent ATO rulings.
06 Apr 11 |
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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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
Julian works for Allens.
Current 1 September 2014