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Transfer Pricing - current issues under the ATO's microscope convention paper

Published on 13 Sep 03 by VICTORIAN DIVISION, THE TAX INSTITUTE

The Australian Taxation Office's (ATO's) June release of its Large Business and Tax Compliance Policy reinforces transfer pricing as a continuing area of major focus. Some may even consider the ATO's views to be extremely aggressive. Using case studies, this paper explores hot topics currently receiving the ATO's attention, such as:
- whether Australian intellectual property is receiving adequate reward and recognition. Is this a risk or an opportunity?
- where functions or risks are moved out of Australia, what effect should this have on profit?
- representative office or distributor? What does this mean?
- what is the position on customs duty paid where the ATO adjusts a company's transfer prices?

Author profile:

Zara RITCHIE
Zara is a partner in the Australian Transfer Pricing practice of PricewaterhouseCoopers Her experience covers a range of industries, which include technology, consumer products, manufacturing and automotive companies. Zara's transfer pricing experience includes assisting clients negotiate successful audit disputes, Advance Pricing Arrangements, develop cost effective and pragmatic documentation strategies as well as cross border structuring and planning advice.
Current at 2 April 2004
Click here to expand/collapse more articles by Zara RITCHIE.
 

This was presented at 42ND VICTORIAN STATE CONVENTION - CELEBRATING SUCCESS .

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Mergers and Acquisitions III

Author(s):  Tim NEILSON

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Taxation of Expatriates

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Review of International Tax

Author(s):  David SCOTT

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Part IVA - Twenty Two Years On - In a state of maturity?

Author(s):  Fiona J ALPINS,  John W DE WIJN

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Contentious Recent Developments

Author(s):  Keith JAMES

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