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Responding to Australia's transfer pricing reforms paper

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 10 May 13 by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE

This paper discusses Australia’s transfer pricing landscape and the ATO’s focus on transfer pricing and profit shifting. Specifically, it offers:

  • an overview of Australian transfer pricing reforms over the past 18 months, and the local / global (OECD) focus on profit shifting and base erosion
  • discussion on both the technical aspects and key practical implications of Australia’s new transfer pricing rules for taxpayers
  • hot topics / focus areas for revenue authorities (e.g. business restructures, financing, intangible property, (marketing) services transactions)
  • an update in terms of the ATO’s transfer pricing compliance enforcement activity – including the International Dealings Schedule, risk reviews and audits.

Author profile

Janelle Sadri
Janelle is an Account Director in the Deloitte Perth transfer pricing practice. Janelle has over 7 years of experience in both corporate/international tax and transfer pricing. Janelle has advised on several significant inbound and outbound structuring projects in the natural resources sector, including finance structuring and debt pricing to support arm’s length gearing / interest levels, and business restructures involving the movement of key profit driving functions and the migration of intellectual property. Janelle has provided advice in relation to the interpretation and application of the arm’s length principle in an MRRT and PRRT context. Janelle has also project managed and successfully negotiated unilateral and bilateral Advance Pricing Arrangements (APAs), delivered regional/global transfer pricing planning and documentation studies, and has assisted clients in transfer pricing risk reviews and audit settlements. Janelle has published articles on transfer pricing issues in Asia Pacific journal
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This was presented at International Day .

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Individual sessions

Key international tax considerations for investing into and out of Australia

Author(s):  Kenneth WEE,  Zubin SADRI

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Tax residency and double tax agreement

Author(s):  Tony UNDERHILL,  Katya KROTOVA

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Tax treaties - What are they and what do they do?

Author(s):  Mathew CHAMBERLAIN

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Cross border transactions and tax controversy

Author(s):  Rob BENTLEY,  Michael BONA

Materials from this session:

Responding to Australia's transfer pricing reforms

Author(s):  Janelle Sadri

Materials from this session:

An update on Government (in)activity

Author(s):  Narelle MCBRIDE,  Nick HEGGART,  Tristan Boyd

Materials from this session:

Further details about this event:

 

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