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Profit attribution to permanent establishments and transfer pricing following the Roche case paper

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?

Author profile:

Nick Houseman CTA
Nick a Partner 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 the Asia-Pacific and Europe and has conducted many in-depth financial and economic analyses throughout the financial services industry. Current at 01 January 2014 Click here to expand/collapse more articles by Nick HOUSEMAN.
 

This was presented at Financial Services Taxation Conference 2009.

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