Published on 19 Jul 06
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
Topics covered in this seminar paper include:
Classifying the related parties based on function, assets and risks "giving each party a functional description" for benchmarking purposes
Tying the classification into how related party pricing is set - for example the use of global price lists.
What are the appropriate methoidologies for setting the prices and testing the outcome for:
(i) a local distributor of imported trading stock
(ii) a local manufacturer and exporter of trading stock
(iii) a service providor both inwards and outwards
What is the difference between a service and a royality and what methodologies are generally recognized for setting and/or testing the arm's length nature of royalities?
If a foreign compant has a permanent establishment or a dependent agent in Australia, what is the methodology adopted by the PE/agent in dealing with its head office and other off shore related parties?
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