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.
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
23 February 2017
Pete is PwC Australia’s national tax leader. Pete leads a national team of over 1,000 passionate and talented experts who have stand-out capability in local and global tax issues. Pete is dedicated to PwC’s strategy to embrace a diverse talent mix, by both increasing the proportion of females in senior roles, as well as increasing the proportion of individuals from diverse cultural backgrounds across the firm. As a leader, Pete proudly fosters an inclusive culture both within his leadership team and throughout the tax practice and broader firm.
- Current at
08 January 2019
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
08 October 2019