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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.

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