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Published on 12 Feb 09
by NATIONAL DIVISION, THE TAX INSTITUTE
The OECD finally released its Report on Attribution of Profits to PEs in July. This paper covers:
so what is the ‘Authorised OECD Approach'?
how will it fit with the ATO's guidance on attribution of profits to PEs in Australia?
what are the important issues for Australian taxpayers to be aware of?
The Roche Case was Australia's first legal decision on a substantive transfer pricing matter since the introduction of Division 13:
what does the decision mean for taxpayers and the ATO?
are profit methods dead?
what does it mean for the financial services sector?
Nick Houseman FTIA is a Partner in Transfer Pricing at PricewaterhouseCoopers, Sydney. Nick has over 15 years experience
advising on transfer pricing matters with a focus on the financial services sector. Nick also has extensive experience in local and
global transfer pricing documentation and compliance, tax planning, negotiations of Advance Pricing Agreements, competent
authority negotiations, litigation support and audit defence in the financial services industry and other industries for well known
Australian and foreign companies. Nick has managed many significant regional and global projects based in Asia-Pacific and
European regions and has conducted many in-depth financial and economic analyses throughout the financial services industry. Current at 11 February 2009
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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