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Transfer pricing - the practicalities of achieving an arm's length outcome presentation
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 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 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
This was presented at 48th Victorian State Convention .
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Transfer pricing - the practicalities of achieving an arm's length outcome
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