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Practical implications and observations from a transfer pricing perspective presentation


This presentation covers:

  • interaction between transfer pricing and thin capitalisation
  • Merkel view
  • TR 2009/D6
  • rule of thumb
  • parental affiliation
  • understand your risk profile.

Author profiles

Chris Thomas
Chris has recently joined PWC after a 24 year career in the Australian Tax Office. Chris has specialised in transfer pricing, focussing on bilateral negotiations, for 15 years. Chris is a highly experienced Competent Authority negotiator and has cultivated excellent working relationships with representatives of many countries including UK, Switzerland, Japan, US, Canada, New Zealand, Germany, France, Singapore, Thailand, Italy, New Guinea and China. - Current at 10 May 2010
Garrick Robinson
Garrick is a partner in the Australian Transfer Pricing practice of PWC based in Perth, with over 15 years' experience specialising in transfer pricing in PwC's Perth, Melbourne and Amsterdam offices. During this time he has developed a wide range of transfer pricing experiences within a number of industries such as resources, logistics, technology, consumer products and industrial products. - Current at 16 January 2012
Click here to expand/collapse more articles by Garrick ROBINSON.


This was presented at Challenges to Funding Structures: Are you at risk? .

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Individual sessions

Certainty in the current tax funding market

Author(s):  Braedon CLARK

Materials from this session:

The Commissioner’s transfer pricing powers and thin capitalisation safe harbours

Author(s):  Toby KNIGHT

Materials from this session:

Practical implications and observations from a transfer pricing perspective

Author(s):  Garrick ROBINSON,  Chris THOMAS

Materials from this session:

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