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The new transfer pricing rules in the context of financial services paper


This paper covers:

  • choice of transfer pricing method
  • re-characterisation of financial transactions
  • use of the OECD commentary
  • interaction with thin capitalisation
  • new documentation requirements
  • OECD developments on transfer pricing documentation and intangibles.

Author profiles:

Author Photo - Kristen Deards FTI
Kristen Deards FTI
Kristen is a Barrister at Banco Chambers in Sydney. She has appeared for taxpayers and the Commissioner of Taxation in tax cases in the Administrative Appeals Tribunal and the Federal Court, and in appeals to the Full Federal Court and the High Court of Australia. Kristen has practised in tax for 15 years, and was called to the Bar in 2006. Kristen has a particular interest in transfer pricing and appeared as junior counsel for the Commissioner in SNF at first instance and on appeal to the Full Federal Court. She is currently briefed by a number of multinationals in transfer pricing disputes with the Commissioner, including a series of transfer pricing appeals by Chevron to be heard in 2014. Current at 18 October 2013 Click here to expand/collapse more articles by Kristen DEARDS.
Sarah Stevens ATI
Sarah is a Director in PwC’s transfer pricing team in Melbourne. Sarah has been a transfer pricing specialist since joining PwC in 1999 and has deep transfer pricing experience in both Australia and Indonesia across a wide range of issues and industries. Sarah has been at the forefront of PwC’s analysis of the new Australian transfer pricing laws including considering the practical issues that multinationals will face in complying with the new rules. Current at 18 October 2013 Click here to expand/collapse more articles by Sarah Stevens.

This was presented at 2014 Financial Services Taxation Conference.

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