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, CTA, currently holds the position in the Australian Taxation Office (ATO) of Assistant Commissioner in the Public Groups & International business line. Mr Jenkins has more than 18 years specialist experience in transfer pricing and related areas of international tax. Mr Jenkins was heavily involved in the development of Australia’s revised transfer pricing legislation (enacted 2013), and subsequently led the ATO team preparing ATO interpretative and other guidance materials relevant to the legislation. In his current role, Mr Jenkins is the ATO’s Chief Economist leading a team of around 70 professional economists. Mr Jenkins has been an Australian delegate to the OECD’s Working Party 6 on transfer pricing matters since 2010, and was also Australian competent authority for transfer pricing matters from 2010-2012.
- Current at
30 August 2017
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
15 September 2017