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Transfer pricing issues in a financial services organisation seminar paper

Published on 19 Mar 04 by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA

This seminar paper covers the following topics:
- intellectual property in a Financial Services organisation: What is it? How do you price it?
- is a CCA an appropriate pricing method? If so, when?
- case study to illustrate the transfer pricing and related income and withholding tax issues.

Author profiles

Damian Preshaw CTA
Damian Preshaw is a transfer pricing specialist with more than 25 years’ experience in both the private sector and with the Australian Taxation Office and provides specialist transfer pricing services to accounting firms and law firms. Prior to establishing Damian Preshaw Consulting Pty Ltd, Damian was a director in KPMG’s Transfer Pricing Services Group in Melbourne for 12 years. In this capacity, Damian advised a wide variety of multinational clients on transfer pricing and profit attribution issues with a special focus on dispute resolution, financial services, financial transactions and business restructuring. Before joining KPMG, Damian was an international tax counsel in the ATO’s Transfer Pricing Practice in Canberra where he was extensively involved in the ATO’s transfer pricing rulings program and was an Australian delegate to the OECD’s Working Party No.6 (Taxation of Multinational Enterprises) from 1994 to 2003. Damian is a Chartered Tax Adviser and represented The Tax Institute on the ATO’s Division 815 Technical Working Group. Damian has twice appeared as a witness before the Senate Economics Legislative Committee’s hearings in relation to Australia’s new transfer pricing rules on behalf of The Tax Institute. - Current at 09 July 2020
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Paul Balkus
Photo of author, Paul BALKUS Paul is the co-leader of Ernst & Young’s Oceania Transfer Pricing practice. He has over 20 years experience in the field of tax and transfer pricing including significant experience in servicing clients across most industries including financial services, mining and resources, pharmaceutical and fast moving consumer goods. Paul has been involved in all aspects of transfer pricing including advance pricing arrangements, dispute resolution, planning and documentation. More specifically, Paul’s experience has included addressing transfer pricing issues in connection with inter-company arrangements involving supply chain restructuring arrangements, global funds management, credit and performance guarantees, global trading and intercompany financing. - Current at 14 July 2017
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This was presented at 2004 Financial Services Taxation Conference: A Brave New World .

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Superannuation Update

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