Published on 14 Sep 05
by VICTORIAN DIVISION, THE TAX INSTITUTE
Topics covered in this paper include:
- what is a Phillips type service trust?
- what the Commissioner said about Phillips type service arrangements prior to the draft ruling
- how does the draft ruling and guidance document impact upon Phillips type service trusts?
- what the guidance document says about the key characteristics of an allowable service trust?
- what characteristics should be avoided in a service trust?
- are there any safe harbours?
- is it necessary to undertake transfer pricing review to determine service fees?
- how important is documentation?
- retrospective impact of the draft ruling
- planning approach - what needs to be done NOW!
Peter is a Senior Tax Partner at KPMG. Peter specialises in advising clients on a broad range of corporate tax
issues and has experience in domestic and international tax matters including advising on mergers and acquisitions, business
tax reform, capital structures, and restructuring international corporate groups. Peter has national responsibility for tax
consolidation for KPMG. Peter has had extensive experience in tax consolidation and participated in a number of Treasury and
Australian Taxation Office consultative groups.
Current at 9 February 2009 Current at 14 May 2009
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