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Treaty shopping paper


This paper covers:

  • prevention of treaty shopping
  • overview of TPG/Myer transaction in the context of treaty shopping
  • addressing treaty shopping in an Australian context.

Author profiles

Jayde Thompson
Jayde is a Senior Manager in the Corporate Tax Services Group of PricewaterhouseCoopers in Melbourne where she specialises in international tax and M&A. Over the past 7 years, Jayde has worked on a large number of domestic and cross border transactions both in Australia and New York. Jayde was recently seconded to the Board of Taxation where she was involved in the review of the Arm's Length Debt Test, Taxation of Financial Arrangements and the post-implementation review of the Debt and Equity tax rules. - Current at 26 November 2015
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Paul Korganow
Photo of author, Paul KORGANOW Paul Korganow, ATI, is the ATO Assistant Commissioner for the International Tax Structuring/BEPS Practice, Public Groups and International. Paul leads an International Tax Structuring team based in Melbourne and Sydney. He is also involved in strategy development and contribution to domestic and multilateral law reform around BEPS. Paul is the ATO Project Lead for BEPS Action 2, the Australian ATO representative at OECD Working Party 11 and represented the ATO on the Board of Taxation Working Group looking at the domestic implementation of the OECD Anti-Hybrid Rules. Paul was previously a Partner at two Big 4 firms in their International Tax and M&A groups. - Current at 16 February 2018
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Chetan Prabhu
Chetan is a Senior Manager at Ernst & Young. - Current at 01 July 2010


This was presented at 49th Victorian State Convention .

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Individual sessions

TOFA - Much Ado?

Author(s):  Mark POOLE

Materials from this session:

Corporate tax governance and risk

Author(s):  Cheryl-Lea FIELD

Materials from this session:

Trust deed issues in a post-Bamford world

Author(s):  Graeme HALPERIN

Materials from this session:

Debt which does not generate assessable income

Author(s):  Cameron RIDER

Materials from this session:

Post-Bamford trustee resolutions

Author(s):  Nabil (Bill) F. OROW

Materials from this session:

The 'new' superannuation environment

Author(s):  Noelle KELLEHER

Materials from this session:

Further details about this event:


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