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Transfer pricing and the cloud - What do multinationals need to consider? paper

Published on 24 Oct 12 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • value of the cloud to an organisation and impact on its functional profile
  • charging for the provision of cloud systems to members of a multinational group
  • centralisation issues
  • attribution of profits to PEs in an e-commerce/cloud environment.

Author profile:

Geoffrey Gill ATI
Geoff is a transfer pricing partner with Deloitte based in Sydney. Geoff leads Deloitte Australia's transfer pricing practice for the financial services industry and also specialises in the analysis of financial transactions. He has advised on many APAs, audits and risk reviews including the first completed joint transfer pricing audit between the ATO and IRS. Recently, Geoff has been closely involved in working with the Australian Treasury on the reforms to Australia's transfer pricing rules. Current at 01 November 2013 Click here to expand/collapse more articles by Geoffrey GILL.
 

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