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What do recent OECD and ATO transfer pricing developments mean for financial institutions paper?

Published on 11 Feb 10 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • attribution of profits to permanent establishments
  • debt pricing
  • other ATO developments
  • other OECD devleopments.

Author profile:

David GRECIAN
David joined Deloitte after 35 years working at the ATO. He has been involved with transfer pricing case work, litigation, public rulings, compliance strategy and policy both domestically and at the OECD for more than 20 years. He also has extensive experience in the Financial Services sector. David is one of the most experienced and influential people in the transfer pricing area and is recognised globally given his position at the OECD for the past six years where he was involved in the development and interpretation of the transfer pricing provisions. David has extensive experience in the financial services industry with both a local and global/OECD perspective, including policy, interpretation and compliance matters. His experience specifically includes public rulings, APAs, transfer pricing audits and litigation of various issues in the financial services sector. He also has particular experience with domestic legislation including Div 820 and Part IIIB.
Current at 18 November 2008
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