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Transfer pricing - The practicalities of achieving an arm's length outcome paper


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.

Author profile:

Keir Cornish
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 03 July 2014 Click here to expand/collapse more articles by Keir CORNISH.

This was presented at 48th Victorian State Convention.

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Bamford v Federal Commissioner of Taxation

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