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Legislative changes to the transfer pricing rules - The practical implications presentation

Published on 18 Sep 13 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers the key practical implications from the changes in the transfer pricing rules, and actions that may be required by taxpayers including:

  • practical examples of how the new laws will apply, focusing on business restructures, intra-group financing and loss making subsidiaries
  • taxpayer profiles and "trigger transactions" impacted by the legislative changes
  • ATO transfer pricing audit focus areas
  • impact on disclosures on the International Dealing Schedule.

Author profile:

Tony Gorgas
Tony is a Partner in KPMG’s Transfer Pricing practice with over 15 years of experience advising multinational groups on complex transfer pricing issues. With prior commercial experience negotiating arm’s length pricing arrangements, Tony provides a practical interpretation of the complex technical rule book. Tony’s abilities to influence and negotiate on behalf of clients are the cornerstone of his reputation. Tony advises a number of the world’s leading enterprises on transfer pricing within Australia and across the ASPAC region. He is KPMG’s leader for a number of clients in the technology and media space. Tony has extensive contacts within the Australian Taxation Office (ATO) and has strong working relationships with the ATO’s Competent Authority. Tony has successfully concluded APAs (Advance Pricing Arrangements) involving a wide variety of transactions including large business restructuring. Tony successfully concluded APAs with key jurisdictions including the US, UK, Japan and Korea, and he has valuable experience in the resolution of Mutual Agreement Proceedings between Competent Authorities. Current at 19 July 2013
 

This was presented at International Masterclass.

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Legislative changes to the transfer pricing rules - The practical implications

Author(s):  Tony Gorgas

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