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Debt pricing – current issues presentation

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.

Author profiles:

David Grecian
David Grecian is currently National Director with Deloitte Touche Tohmatsu in Melbourne. David has nearly 30 years’ experience in transfer pricing case work, litigation, public rulings and policy. As Chair of the OECD WP6 and the Steering Group on transfer pricing in Paris, he was the senior official responsible for the development of the OECD report on attribution of profits to permanent establishments, including banking, global trading and insurance. Current at 03 September 2010 Click here to expand/collapse more articles by David GRECIAN.
 
Michael Jenkins CTA
Michael has worked in the area of transfer pricing and international tax for around 15 years, both in the ATO and in a professional services environment. He is currently an Assistant Commissioner in the Public Groups & Internationals business line of the ATO. Michael is involved in a number of major transfer pricing cases, and leads a team involved in the development of the ATO’s guidance products related to the transfer pricing provisions enacted in 2013. He is currently the Australian delegate to the OECD’s Working Party No. 6 on transfer pricing matters, and was the Australian competent authority for transfer pricing matters from 2010 to 2012. Current at 02 June 2015 Click here to expand/collapse more articles by Michael JENKINS.
Individual sessions

Debt pricing – current issues

Author(s):  Michael JENKINS,  David GRECIAN

Materials from this session:

Further details about this event:

 

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