Published on 09 Oct 09
by VICTORIAN DIVISION, THE TAX INSTITUTE
Taxpayers and the revenue authorities are grappling with how to translate transfer pricing theory into a workable approach. This paper discusses:
- the challenges of making adjustments to target a profit result
- navigating the ATO and OECD views on business restructuring where not just pricing but decision making may be open to review
- opportunities under the ATOs renewed APA program
- dealing with current ATO compliance activities.
Keir Cornish is A/g Assistant Commissioner of the Foreign Investment Program, which provides advice to Treasury on the tax issues arising from foreign investment proposals, administers foreign investment in residential property, and manages Federal registers of foreign investment in agricultural land and water entitlements. Keir joined the ATO in in 2018 and has worked on a range of projects including the Inbound Supply Chain PCG, the APA program, and the MLI capability build. Prior to joining the ATO, Keir worked in professional services as a tax advisor, with 10 years as a partner at Ernst & Young specialising in transfer pricing.
- Current at
19 July 2019