8:30–9:15am Registration
9:15–9:30am Welcome and opening address
Damian Preshaw, CTA, National Transfer Pricing Conference Chair
9:30–10:30am Session 1: Keynote address
10:30–11:00am Morning tea
11:00am–12:00pm Session 2A: Taking the (transfer pricing) heat out of investing into Australia
Michelle Sams, Australian Taxation Office
Session 2B: Inbound vs outbound: Do the transfer pricing rules apply in the same way
12:00–1:00pm Session 3: Addressing the tax challenges of digitalisation – Recent developments and potential issues arising in relation to Pillar 2
Ann-Maree Wolff, CTA, Rio Tinto; Natalie Chang, FTI, Rio Tinto
1:00–2:00pm Lunch
2:00–3:00pm Session 4A: DPT cases before the Federal Court! What does it mean for MNE groups?
Facilitator: Dr Niv Tadmore, CTA, Jones Day
Panellists:
Fiona Dillon, CTA, Chief Tax Counsel, ATO
Jennifer Davies SC, Victorian Bar
Session 4B: Revisiting use of profit split methods in light of the revised guidance in the 2022 OECD Transfer Pricing Guidelines
Natalya Marenina, BDO; Filippo Miotto, BDO
3:00–3:30pm Afternoon Tea
3:30–4:30pm Session 5A: The Commissioner’s ability to access information in transfer pricing cases
Facilitator: Fiona Moore, CTA, EY
Panellists:
Dioni Perera, FTI, EY
Monisha Sequeira, Allens
Session 5B: ATO draft ruling on the character of receipts relating to software: To withhold or not to withhold?
Neil Pereira, CTA, Deloitte, Priscilla Ratilal, Deloitte
4:30–5:30pm Session 6: Commercial rationality: why does it matter and how do I prove it?
Martin Fry, FTI, Allens; Thomas Ickeringill, FTI, Allens; Jason Vella, ATI, EY
5:30–7:30pm Networking function
