Published on 14 Mar 12
by NATIONAL DIVISION, THE TAX INSTITUTE
This presentation covers:
- transfer pricing in Australia
- Australian transfer pricing cases:
- SNF (Australia) Pty Ltd v Comr
- Roche Products Pty Ltd v Comr
- legal and practical implications
- proposed legislative changes to Division 13.
Pete Calleja is a Partner in the transfer pricing practice of PwC
Sydney and also currently leads the PwC Asia Pacific transfer
pricing practice. He has more than 13 years of tax and transfer
pricing experience and has conducted a wide variety of complex
cross-border business transformation projects, successfully
agreeing numerous multilateral Advance Pricing Agreements
(APA) and resolving TP disputes through the Mutual Agreement
Procedure (MAP) process.
- Current at
01 March 2012
Paul is a Partner and solicitor in the Tax Controversy practice in PwC Sydney. Paul has more than thirty years of taxation experience and has published and spoken on a wide range of taxation issues throughout that period. Over the last 20 years he has had extensive experience in assisting clients understand the tax risks they face and manage their interactions with the ATO. His client base includes some of Australia and the world's largest multinationals and the information technology and telecommunications sectors are particularly heavily represented. His work has included planning for and review of significant transactions (including business value chain transformations), assistance with the assessment and disclosure of tax risk to statutory auditors, management of audits by the ATO and negotiation of settlements and the preparation and conduct of litigation.
- Current at
23 February 2017