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Practical implications arising from changes in the Australian transfer pricing legislation presentation


The current and proposed changes to the transfer pricing legislation have potentially significant implications for many taxpayers that will need to be addressed. This presentation provides an overview of the background and drivers for the legislative changes as well as the practical implications and actions that may be required by taxpayers.

The presentation covers:

  • background and drivers for change in the Australian transfer pricing legislation
  • implications for historical and future  transfer pricing positions
  • taxpayer profiles and  "trigger transactions" impacted by the legislative changes
  • treaty partner considerations
  • transfer pricing documentation and disclosure requirements.

Author profile

Paul Balkus
Photo of author, Paul BALKUS Paul is the co-leader of Ernst & Young’s Oceania Transfer Pricing practice. He has over 20 years experience in the field of tax and transfer pricing including significant experience in servicing clients across most industries including financial services, mining and resources, pharmaceutical and fast moving consumer goods. Paul has been involved in all aspects of transfer pricing including advance pricing arrangements, dispute resolution, planning and documentation. More specifically, Paul’s experience has included addressing transfer pricing issues in connection with inter-company arrangements involving supply chain restructuring arrangements, global funds management, credit and performance guarantees, global trading and intercompany financing. - Current at 14 July 2017
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This was presented at International Masterclass 2012 .

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Individual sessions

Practical implications arising from changes to the Australian transfer pricing legislation

Author(s):  Paul BALKUS

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Exchange of and access to information

Author(s):  Michael O'NEILL,  David ALLEN

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