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Challenges to Funding Structures: Are you at risk?

Published on 04 May 2010 | Took place at RACV Club, Melbourne, VIC

Recently the ATO has increased its focus on deductions arising from cross-border debt structures. This is evidenced by current audit activity with regard to interest paid to foreign affiliates, the ATOs review of section 25-90, its Taxpayer Alert 2009/09 and the release of TR2009/D6.

This event deconstructed some of the current thinking on the pricing of intra-group debt, the legality of the Commissioner's powers with regard to transfer pricing and discussed the practicalities of complying with the Commissioner's rule of thumb.

Get a 20% discount when you buy all the items from this event.

Individual sessions

Certainty in the current tax funding market

Author(s):  Braedon CLARK This presentation covers:

  • using the ROT
  • GE case - guarantee fees
  • credit ratings
  • Westpac v CIR
  • what can we learn from these foreign cases?
  • intra-group inbound funding.
Materials from this session:

The Commissioner’s transfer pricing powers and thin capitalisation safe harbours

Author(s):  Toby KNIGHT This presentation covers:

  • transfer pricing
  • Division 820
  • results under different ATO documents
  • effects of potential ATO adjustments
  • Division 13
  • associated enterprise article.
Materials from this session:

Practical implications and observations from a transfer pricing perspective

Author(s):  Garrick ROBINSON,  Chris THOMAS This presentation covers:

  • interaction between transfer pricing and thin capitalisation
  • Merkel view
  • TR 2009/D6
  • rule of thumb
  • parental affiliation
  • understand your risk profile.
Materials from this session: