Published on 12 Feb 09
by NATIONAL DIVISION, THE TAX INSTITUTE
The OECD finally released its Report on Attribution of Profits to PEs in July. This presentation covers:
so what is the ‘Authorised OECD Approach'?
how will it fit with the ATO's guidance on attribution of profits to PEs in Australia?
what are the important issues for Australian taxpayers to be aware of?
The Roche Case was Australia's first legal decision on a substantive transfer pricing matter since the introduction of Division 13:
what does the decision mean for taxpayers and the ATO?
are profit methods dead?
what does it mean for the financial services sector?
Nick Houseman FTIA is a Partner in Transfer Pricing at PricewaterhouseCoopers, Sydney. Nick has over 15 years experience advising on transfer pricing matters with a focus on the financial services sector. Nick also has extensive experience in local and global transfer pricing documentation and compliance, tax planning, negotiations of Advance Pricing Agreements, competent authority negotiations, litigation support and audit defence in the financial services industry and other industries for well known Australian and foreign companies. Nick has managed many significant regional and global projects based in Asia-Pacific and European regions and has conducted many in-depth financial and economic analyses throughout the financial services industry.
- Current at
30 August 2017
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
All materials provided on this site are protected by copyright and are owned by or licensed to TTI.
Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.