Published on 14 Oct 02
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This powerpoint presentation discusses disputes in the transfer pricing area, including: a review of the current ATO programmes, areas of dispute/contention and the ATO's response, role of the APA programme in resolving/eliminating disputes, impact of foreign jurisdictions/jurisprudence, and litigation vs. competent authority.
Andrew is a partner in Deloitte's Pricing and Economics Group. After many years as a corporate tax practitioner Andrew began specialising in transfer pricing issues in 1994. In 1997 Andrew transferred to the Los Angeles office of Deloitte & Touche, where he spent approximately three years as part of the US transfer pricing team. During this period Andrew's work focused on examination of the steps in the value chain contributing to the total income of a business and structuring intercompany arrangements to appropriately reward the participants while managing the incidence of taxation. Andrew returned to the Australian practice in August 2000. Since then he has been involved in assisting clients with setting and documenting arm's length prices and advising on audit settlements, Mutual Agreement Proceedings and APAs with particular emphasis on the technology and consumer products sectors.
- Current at
22 September 2005