Published on 18 Nov 08
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
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.
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
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
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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