Published on 14 Sep 11
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper covers:
- the SNF decision
- evidentiary challenges
- attempts to stem the tide of losses
- evidence of a global market
- OECD guidelines
- Roche Australia v the Commissioner of Taxation
- relevant facts
- expert reports
- appropriate choice of comparables
- contract between RB and Bayer AG ("Inhibace")
- choice of OECD methodology.
Colin is a Partner leading the Tax Controversy practice of Deloitte in Sydney. With over eighteen years in the
taxation field, for the past ten years Colin has focussed in assisting both public and private sector clients resolve
complex taxation disputes, ranging from audit negotiation and resolution through to litigation in the Federal,
Supreme and High Court. Colin previously worked with another big four Controversy practice assisting a range
of multinational, large corporate and high net worth clients. Current at 18 March 2016
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Pete Calleja is a Partner in the transfer pricing practice of PwC
Sydney and also currently leads the PwC Asia Pacific transfer
pricing practice. He has more than 13 years of tax and transfer
pricing experience and has conducted a wide variety of complex
cross-border business transformation projects, successfully
agreeing numerous multilateral Advance Pricing Agreements
(APA) and resolving TP disputes through the Mutual Agreement
Procedure (MAP) process. Current at 01 March 2012
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Paul McNab CTA
Paul is a Partner and solicitor in the Tax Controversy practice in PwC Sydney. Paul has more than thirty years of taxation experience and has published and spoken on a wide range of taxation issues throughout that period. Over the last 20 years he has had extensive experience in assisting clients understand the tax risks they face and manage their interactions with the ATO. His client base includes some of Australia and the world's largest multinationals and the information technology and telecommunications sectors are particularly heavily represented. His work has included planning for and review of significant transactions (including business value chain transformations), assistance with the assessment and disclosure of tax risk to statutory auditors, management of audits by the ATO and negotiation of settlements and the preparation and conduct of litigation. Current at 01 April 2015
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