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The authorised OECD approach… or is it? paper


Transfer pricing is consistently rated as one of the major tax issues by tax directors and CFOs of
large multinational organisations. While transfer pricing rules are common across all industries,
unique characteristics present in the financial services industry: the rules can raise complex issues in their application.

This paper:

  • identifies the hot current and future issues affecting financial service organisations
  • shares practical experiences of the recent OECD guidelines covering attribution of profits to PEs, global trading and insurance
  • advises of the high ATO risk areas for the Industry.

Author profile:

David joined Deloitte after 35 years working at the ATO. He has been involved with transfer pricing case work, litigation, public rulings, compliance strategy and policy both domestically and at the OECD for more than 20 years. He also has extensive experience in the Financial Services sector. David is one of the most experienced and influential people in the transfer pricing area and is recognised globally given his position at the OECD for the past six years where he was involved in the development and interpretation of the transfer pricing provisions. David has extensive experience in the financial services industry with both a local and global/OECD perspective, including policy, interpretation and compliance matters. His experience specifically includes public rulings, APAs, transfer pricing audits and litigation of various issues in the financial services sector. He also has particular experience with domestic legislation including Div 820 and Part IIIB.
Current at 18 November 2008 Current at 12 January 2009 Click here to expand/collapse more articles by David GRECIAN.


This was presented at 2008 Financial Services Conference .

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