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 leads the Melbourne Transfer Pricing Practice of EY, with 20 years of experience advising large corporate taxpayers, and more than 15 years as a profit-shifting specialist. Keir works with large and medium corporates to manage complex transfer pricing issues that impact tax risk and corporate reputation. Recent projects cover a range of business restructuring, financing, tax audit, BEPS, APAs and reporting matters.
- Current at
31 March 2010