Published on 30 Apr 08
by VICTORIAN DIVISION, THE TAX INSTITUTE
This presentation covers:
- credit rating issues relevant to MNEs and parts of MNEs (including discussion on the approaches used by credit rating agencies and interaction with the arm's length principle)
- pricing methodologies
- interaction of Australia's thin capitalisation rules and transfer pricing rules
- the concept of ‘arm's length' capital structures in transfer pricing.
Michael Jenkins FTIA is a principal at Deloitte with 10 years experience in transfer pricing covering various industry sectors. In recent times Michael has focused on transfer pricing issues relating to the pricing of debt and related issues.
Current at 21 August 2008 Current at 16 September 2008
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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 Current at 12 January 2009
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