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 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
29 July 2016
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
10 December 2009