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Transfer pricing – How much does your debt cost paper?

Published on 18 Nov 08 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper:

  • outlines the transfer pricing impacts of the global credit crunch
  • discusses how to determine arm's length interest rates and take account of key factors such as borrower credit worthiness and characteristics of the loan
  • discusses the practical impact of the ATO's recent publications on the issue of debt finance, and the major areas of controversy
  • provides practical guidance on how to deal with the thorny issue of how to price loan guarantees.

Author profiles:

David GRECIAN
David joined Deloitte after 35 years working at the ATO. He has been involved with transfer pricing case work, litigation, public rulings, compliance strategy and policy both domestically and at the OECD for more than 20 years. He also has extensive experience in the Financial Services sector. David is one of the most experienced and influential people in the transfer pricing area and is recognised globally given his position at the OECD for the past six years where he was involved in the development and interpretation of the transfer pricing provisions. David has extensive experience in the financial services industry with both a local and global/OECD perspective, including policy, interpretation and compliance matters. His experience specifically includes public rulings, APAs, transfer pricing audits and litigation of various issues in the financial services sector. He also has particular experience with domestic legislation including Div 820 and Part IIIB.
Current at 18 November 2008 Current at 12 January 2009 Click here to expand/collapse more articles by David GRECIAN.
 
Author Photo - Geoff GILL
Geoff GILL
Geoff is a partner and senior economist with Deloitte’s Global Transfer Pricing group in Sydney. Geoff’s key focus area is the financial services industry including transfer pricing issues associated with debt funding, and he has published a number of articles and spoken at external seminars in this area.
Current at 18 November 2008 Current at 27 April 2009 Click here to expand/collapse more articles by Geoff GILL.

 

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