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Disputes in the transfer pricing area: where are we up to and where are we heading to?

Published on 14 Oct 02 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This seminar discusses disputes in the transfer pricing area, including: a review of the current ATO programmes, areas of dispute/contention and the ATO's response, role of the APA programme in resolving/eliminating disputes, impact of foreign jurisdictions/jurisprudence, and litigation vs. competent authority.

Author profile:

Andrew Fisher CTA
Andrew is a partner in Deloitte's Pricing and Economics Group. After many years as a corporate tax practitioner Andrew began specialising in transfer pricing issues in 1994. In 1997 Andrew transferred to the Los Angeles office of Deloitte & Touche, where he spent approximately three years as part of the US transfer pricing team. During this period Andrew's work focused on examination of the steps in the value chain contributing to the total income of a business and structuring intercompany arrangements to appropriately reward the participants while managing the incidence of taxation. Andrew returned to the Australian practice in August 2000. Since then he has been involved in assisting clients with setting and documenting arm's length prices and advising on audit settlements, Mutual Agreement Proceedings and APAs with particular emphasis on the technology and consumer products sectors. Current at 22 September 2005 Click here to expand/collapse more articles by Andrew FISHER.
 

This was presented at First Class Ticket to Cross Border Taxation.

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Individual sessions


Outbound investment - financing international operations

Author(s):  Alf CAPITO

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GST and customs duty in cross border transactions

Author(s):  Brenda GODLEY

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Australia's tax treaty policy

Author(s):  Richard J VANN

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