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Tying the functional analysis in to common transacations and acceptable methodologies seminar paper

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?

Author profile:

Douglas Fone
Doug is the Australia and Asia Pacific leader of the specialist tax valuation and transfer pricing consultancy, Transfer Pricing Associates (TPA). Prior to joining the TPA group in 2005, Doug had over 15 years of tax and transfer pricing experience with PricewaterhouseCoopers in Hong Kong, Singapore and Australia. He has assisted many multinational clients in Australia and the region with design of transfer pricing systems, preparation of transfer pricing documentation, design and implementation of planning initiatives, resolution of transfer pricing audits and negotiation of Advance Pricing Agreements. Current at 14 June 2006 Click here to expand/collapse more articles by Doug FONE.
 

This was presented at Transfer Pricing - let's get to the point!.

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Individual sessions

Benchmarking - where do you find data to support your arm's length pricing

Author(s):  Chris BOWMAN

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