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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

Kristen Deards SC
Photo of author, Kristen DEARDS Kristen has an extensive taxation practice and appears for taxpayers and the Commissioner of Taxation in income tax and GST cases in the Administrative Appeals Tribunal, the Federal Court and the High Court of Australia. She has appeared in a large range of tax cases, led and unled, from complex Part IVA and transfer pricing cases, to disputes concerning CGT, the consolidation regime, international tax, superannuation, insurance, trusts and charities. An income tax practitioner for fifteen years, Ms Deards has an extensive opinion practice advising corporate taxpayers and high wealth individuals, and she regularly advises taxpayers on the conduct of audits undertaken by the Commissioner of Taxation. - Current at 31 May 2019
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Sarah Stevens ATI
Sarah Stevens is a transfer pricing specialist in PwC’s Global Tax team in Sydney. Sarah has specialised in transfer pricing since joining PwC in 1999 and has deep transfer pricing experience across a wide range of issues and industries, and has also supported clients to review their cross-border arrangements in light of other international tax rules such as the diverted profits tax and hybrid mismatch rules. Sarah has assisted numerous clients to review their cross-border funding arrangements in light of the ATO's risk assessment framework in PCG 2017/4. - Current at 12 June 2019


This was presented at 2014 Financial Services Taxation Conference .

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