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Latest developments in Transfer Pricing presentation

Published on 29 Aug 12 by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE

This presentation provides practitioners with an insight into the latest Australian Transfer Pricing Developments, including:

  • Division 815A – first tranche of proposed transfer pricing reforms and practical implications for multinational taxpayers
  • International Dealings Schedule implications
  • ATO activity and current focus areas.

Author profile:

Janelle Sadri
Janelle is an Account Director in the Deloitte Perth transfer pricing practice. Janelle has over 7 years of experience in both corporate/international tax and transfer pricing. Janelle has advised on several significant inbound and outbound structuring projects in the natural resources sector, including finance structuring and debt pricing to support arm’s length gearing / interest levels, and business restructures involving the movement of key profit driving functions and the migration of intellectual property. Janelle has provided advice in relation to the interpretation and application of the arm’s length principle in an MRRT and PRRT context. Janelle has also project managed and successfully negotiated unilateral and bilateral Advance Pricing Arrangements (APAs), delivered regional/global transfer pricing planning and documentation studies, and has assisted clients in transfer pricing risk reviews and audit settlements. Janelle has published articles on transfer pricing issues in Asia Pacific journal
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Latest developments in Transfer Pricing

Author(s):  Janelle Sadri

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