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Transfer pricing – How much does your debt cost paper?


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 Grecian is currently National Director with Deloitte Touche Tohmatsu in Melbourne. David has nearly 30 years’ experience in transfer pricing case work, litigation, public rulings and policy. As Chair of the OECD WP6 and the Steering Group on transfer pricing in Paris, he was the senior official responsible for the development of the OECD report on attribution of profits to permanent establishments, including banking, global trading and insurance. - Current at 03 September 2010
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Geoffrey Gill ATI
Photo of author, Geoff GILL 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
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Individual sessions

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