Peter Calleja ATIA (PWC) attended the NTLG Transfer Pricing Subcommittee meeting on Wednesday 5 August 2009. The ATO provided an update on the findings of a 'Financial Markets Working Group' (FMWG) formed to consider how financial markets operate and how market outcomes should impact the ATO's views on certain issues raised by intra-group financial transactions, including thin capitalisation, credit guarantees, and the pricing of intra-group credit and credit support (i.e., so-called 'passive association'). The balance of the meeting focused on the:
- APA Program review update;
- Customs Practice Statements;
- ATO Transfer Pricing Compliance Program;
- International Dealings Schedule; and
- Application of Division 13 to equity.