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Transfer pricing - the practicalities of achieving an arm's length outcome presentation


Taxpayers and the revenue authorities are grappling with how to translate transfer pricing theory into a workable approach. This presentation covers:

  • 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 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
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This was presented at 48th Victorian State Convention .

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Individual sessions

Managing trust losses

Author(s):  Meagan O'CONNOR,  Rob JEREMIAH

Materials from this session:

Division 7A the 'sleeping giant'

Author(s):  David STAVROPOULOS

Materials from this session:

Bamford v Federal Commissioner of Taxation

Author(s):  Terry MURPHY

Materials from this session:

Trusts and distribution resolutions in the light of Bamford

Author(s):  Nabil (Bill) F. OROW

Materials from this session:

Inbound investment emerging issues

Author(s):  Vik KHANNA

Materials from this session:

Further details about this event:


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